T.C. Memo. 2000-122
UNITED STATES TAX COURT
ROBERT and MILDRED PEACO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8273-99. Filed April 6, 2000.
Michael B. Yulsman, for petitioners.
Carol-Lynn E. Moran and Kenneth J. Rubin, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notice dated February 10, 1999, respondent
determined a deficiency of $218,903 relating to petitioners’ 1995
Federal income tax. 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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