T.C. Memo. 1995-575
UNITED STATES TAX COURT
WINTHROP B. AND SALLY L. ORGERA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17414-93. Filed December 4, 1995.
William D. Hartsock,1 for petitioners.
Sherri S. Wilder, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a $99,344 deficiency
in petitioners' 1990 income tax. Respondent also determined a
$19,869 penalty under section 6662(a).2 The deficiency includes
1 William D. Hartsock entered his appearance after trial for
involvement in posttrial briefing.
2 Section references are to the Internal Revenue Code in
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