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.
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