T.C. Memo. 1996-260
UNITED STATES TAX COURT
PATRICK W. HEALEY AND NANCY L. MARSHALL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 222-94, 2613-95. Filed June 6, 1996.
Patrick W. Healey, for petitioners.
Lisa K. Hartnett, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined that petitioners are
liable for a deficiency in Federal income tax, an addition to
tax, and a penalty as follows:
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