T.C. Memo. 1997-503
UNITED STATES TAX COURT
DAVID E. AND CHERYL G. SMITH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17071-95. Filed November 10, 1997.
Jon R. Vaught, for petitioners.
Kimberley J. Peterson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent, by means of a statutory notice
of deficiency, determined the following income tax deficiencies
and section 6662(a)1 penalties with respect to petitioners:
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years under
consideration, and all Rule references are to this Court's Rules
of Practice and Procedure.
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