T.C. Memo. 1999-9 UNITED STATES TAX COURT FERYDOUN AHADPOUR, A.K.A. F. AHADPOUR, AND DORIS AHADPOUR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4843-96. Filed January 21, 1999. William K. Norman and Edi Stiles, for petitioners. Louis Jack and Elizabeth Stetson, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION NAMEROFF, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners’ Federal income taxes, additions to tax, and penalties as follows: 1 All section references are to the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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