T.C. Memo. 1997-43
UNITED STATES TAX COURT
PETER S. PAU AND SUSANNA H. PAU, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20475-94. Filed January 27, 1997.
John M. Youngquist, for petitioners.
Patricia Anne Golembiewski, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge: Respondent determined a deficiency in and a
penalty on petitioners' 1990 Federal income tax as follows:
Penalty
Year Deficiency Sec. 6662(a)
1990 $438,692 $61,040
On November 7, 1994, the Paus filed a petition with this
Court. An answer was filed on December 20, 1994, in which
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