T.C. Memo. 2000-46
UNITED STATES TAX COURT
DAN E. AND SUSAN J. MARTENS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4652-98. Filed February 10, 2000.
Lawrence R. Jones, Jr., for petitioners.
Candace M. Williams, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notice dated December 10, 1997, respondent
determined deficiencies of $21,977 and $7,266, and section
6662(a) penalties of $4,395 and $1,453, relating to petitioners’
1993 and 1994 Federal income taxes, respectively. All section
references are to the Internal Revenue Code in effect for the
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