T.C. Memo. 2000-204
UNITED STATES TAX COURT
JAMES E. AND SHIRLEY S. DEAS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11847-99. Filed June 30, 2000.
James E. Deas, pro se.
Francis C. Mucciolo, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge: Respondent determined a $27,629 deficiency in,
and an $5,526 accuracy-related penalty on, petitioners' Federal
income tax for the 1992 taxable year.
After concessions,1 the sole issue for decision is whether
1Petitioners concede that they failed to report $165,000 of
capital gain in either their return or in an amended return for
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