T.C. Memo. 1995-537 UNITED STATES TAX COURT S. VICTORIA WELLS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16962-93. Filed November 13, 2995. Carl F. Agren, for petitioner. Maria D. Murphy, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, Judge: Respondent determined a deficiency in petitioner's 1989 Federal income tax in the amount of $150,027 and an accuracy-related penalty under section 6662(a)1 in the amount of $30,005. The issues for our consideration are: (1) 1 All section references are to the Internal Revenue Code in effect for the taxable year under consideration, and all Rule references are to this Court's Rules of Practice and Procedure, unless otherwise indicated.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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