T.C. Memo. 1999-204
UNITED STATES TAX COURT
R. SCOT STOKES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8936-97. Filed June 21, 1999.
John R. Riley, for petitioner.
David W. Sorensen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge: Respondent determined a deficiency of $25,318
in petitioner's Federal income tax for 1994 and an accuracy-
related penalty of $4,916 under section 6662(a).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
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