T.C. Memo. 1998-209
UNITED STATES TAX COURT
JOHN J. MALONEY and MARY FRANCES MALONEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4421-96. Filed June 16, 1998.
Gregory R. Noonan, for petitioners.
George D. Curran, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: In a notice of deficiency issued on January
22, 1996, respondent determined deficiencies, additions to tax,
and civil fraud penalties relating to John and Mary Maloney's
1984 and 1986 Federal income taxes. The parties have settled all
issues relating to the 1984 tax year. Among the issues relating
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