T.C. Memo. 1995-583
UNITED STATES TAX COURT
HAROLD T. AND CHRISTINE B. COUCH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22110-93. Filed December 6, 1995.
Joseph D. Anroman, for petitioners.
Carmino J. Santaniello, for respondent.
MEMORANDUM OPINION
RAUM, Judge: The Commissioner determined a $10,962
deficiency in petitioners' 1990 income tax plus a section
6662(a)1 penalty in the amount of $2,192. The issues for
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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