T.C. Memo. 1999-276
UNITED STATES TAX COURT
CHARLES T. WICKERSHAM AND SANDRA J. WICKERSHAM, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14562-97. Filed August 20, 1999.
George W. Connelly, Jr., and Linda S. Paine, for
petitioners.
Wanda M. Cohen and R. Scott Shieldes, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$97,899 and a penalty pursuant to section 6663(a) of $73,424 with
respect to petitioners' 1989 Federal income tax.1
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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