T.C. Memo. 2001-185 UNITED STATES TAX COURT DON L. AND LORA CHRISTENSEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16479-99. Filed July 23, 2001. Barbara Sue Geil, for petitioners. Timothy S. Sinnott, for respondent. MEMORANDUM OPINION COUVILLION, Special Trial Judge: Respondent determined that petitioners were liable for the following additions to tax for the years 1982 and 1983:1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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