T.C. Memo. 1997-19
UNITED STATES TAX COURT
P. DAVID MUSGRAVE AND BARBARA J. MUSGRAVE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20374-94. Filed January 9, 1997.
Martin J. Horwitz, for petitioners.
Nancy Ortmeyer Kuhn and Matthew J. Fritz, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge: Respondent determined a deficiency of $20,343
in petitioners' 1990 Federal income tax, an addition to tax
pursuant to section 6651(a)(1) of $936, and an accuracy-related
penalty pursuant to section 6662 of $4,069.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
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