T.C. Memo. 1995-593
UNITED STATES TAX COURT
DAVID RENDEL AND RACHEL RENDEL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11878-93. Filed December 14, 1995.
David M. Kirsch, for petitioners.
Allan D. Hill, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge: Respondent determined a deficiency in
petitioners' 1983 Federal income tax and additions to tax for
fraud and for a substantial underpayment of tax as follows:
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