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.
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