T.C. Memo. 1995-598
UNITED STATES TAX COURT
RICHARD SOO KIM AND DONNA KIM, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24243-93. Filed December 19, 1995.
Richard Soo Kim and Donna Kim, pro se.
Brently W. Free, for respondent.
MEMORANDUM OPINION
COHEN, Judge: Respondent determined a deficiency of $90,593
in petitioner's Federal income tax for 1990 and an addition to
tax of $18,118.60 pursuant to section 6662(a). Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect for the year in issue, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
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