T.C. Memo. 1996-118
UNITED STATES TAX COURT
MTS INTERNATIONAL, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
ROBERT C. HUGHES III, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 2161-93, 2247-93.1 Filed March 12, 1996.
Gary L. Goble, for petitioners.
Frederick W. Krieg and D. Lyndell Pickett, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioners’ Federal income tax and additions to tax as follows:
1 These cases were consolidated for purposes of trial,
briefing, and opinion.
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