T.C. Memo. 2001-242
UNITED STATES TAX COURT
MICHAEL L. AND SUSAN BARNARD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11118-99. Filed September 17, 2001.
Carolyn J. Jackson and Richard Craig Krause, for
petitioners.
Alexandra E. Nicholaides and Timothy S. Murphy, for
respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine respondent’s determination of deficiencies in their
1987, 1988, and 1989 Federal income taxes, additions to their
1987 and 1988 taxes for fraud, and a penalty for fraud as to
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