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.
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