T.C. Memo. 2000-325
UNITED STATES TAX COURT
R. GEORGE AND PENNEY GREGERSEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18076-97. Filed October 19, 2000.
John M. Bradley and Thomas R. Barton, for petitioners.
Mark H. Howard, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notice dated June 13, 1997, respondent
determined a deficiency of $18,504 and a section 6662 accuracy-
related penalty of $3,701 relating to petitioners’ 1994 Federal
income taxes. 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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