T.C. Memo. 2001-264
UNITED STATES TAX COURT
LEROY AND SHIRLEY COMBS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9198-00. Filed October 3, 2001.
Leroy and Shirley Combs, pro sese.
Dale A. Zusi, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notice dated May 24, 2000, respondent
determined a $298,992 deficiency, a $74,598 section 6651(a)
addition to tax, and a $59,798 section 6662(a) penalty relating
to petitioners’ 1994 Federal income tax. All section references
are to the Internal Revenue Code in effect for the year in issue.
The issues for decision are whether petitioners failed to report
income for 1994 and are liable for a section 6651 addition to
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