T.C. Memo. 1999-283
UNITED STATES TAX COURT
THOMAS J. MITCHELL AND JANICE M. MITCHELL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14056-98. Filed August 25, 1999.
Arthur G. Jaros, Jr., for petitioners.
William I. Miller, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine Federal income tax deficiencies of $13,517 for 1994
and $14,407 for 1995 and accuracy-related penalties of $2,703 for
1994 and $2,881 for 1995 for substantial understatement of income
tax. Following concessions, we must decide whether petitioners
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