BARNES v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 20413-08.

T.C. Memo. 2012-80

MARC S. BARNES AND ANNE M. BARNES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 21, 2012.


Attorney(s) appearing for the Case

Gerald W. Kelly, Jr. , and Matthew F. Penater , for petitioners.

Erin R. Hines , for respondent.


MEMORANDUM OPINION

MORRISON, Judge.

Marc S. Barnes and Anne M. Barnes filed a joint income-tax return for tax year 2003. At all relevant times, the Barneses were husband and wife.

On June 3, 2008, respondent ("the IRS") issued the Barneses a statutory notice of deficiency, determining a deficiency in tax of $54,486, a section 6662(a)1 accuracy-related penalty of $10,897, and a section 6651(a)(1...

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