T.C. Memo. 1999-416
UNITED STATES TAX COURT
ROBERT C. AND DIANA J. WATTS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9289-98. Filed December 23, 1999.
Cheryl Frank and Gerald W. Kelly, Jr., for petitioners.
Elizabeth A. Owen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioners’ Federal income tax and an addition to tax and a
penalty as follows:
Addition to tax and penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662
1994 $3,624 $7,035 $5,628
1995 5,150 2,431 2,567
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