T.C. Memo. 1997-493
UNITED STATES TAX COURT
GARY B. AND KATHLEEN MITCHELL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20851-95. Filed November 3, 1997.
Douglas Scott Maynard and Basis J. Boutris, for
petitioners.
Michael F. Steiner and Dale A. Zusi, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined income tax
deficiencies for petitioners' 1987 and 1988 taxable years in the
amounts of $24,716 and $91,878, respectively. Respondent also
determined additions to tax for negligence in the amounts of
$1,236 for 1987 and $4,594 for 1988. After considering
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