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 (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 Next
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