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LORD v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 19224-18.

T.C. Memo. 2022-14

JOHN D. LORD AND BELINDA LORD, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 1, 2022.

Attorney(s) appearing for the Case

Jennifer E. Benda , for petitioners.

Luke D. Ortner and Tamara L. Kotzker , for respondent.

MEMORANDUM OPINION

In a notice of deficiency (notice) dated July 3, 2018, respondent determined that petitioners had a deficiency of $376,299 and an accuracy-related penalty pursuant to section 6662(a) of $75,260 for 2012. In the notice respondent made adjustments to passthrough income petitioners received from two businesses...

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