T.C. Memo. 1999-257
UNITED STATES TAX COURT
HAROLD F. AND BARBARA J. SWIATEK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10978-97. Filed August 4, 1999.
Harold F. Swiatek and Barbara J. Swiatek, pro sese.
Deborah Stanley, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined a deficiency in
petitioners' 1991 Federal income tax in the amount of $95,283 and
a section 6662 accuracy-related penalty in the amount of $19,057.
The dispute in this case centers on respondent's determination
that petitioners had $295,315 of unreported income in 1991, and
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