T.C. Memo. 2001-163
UNITED STATES TAX COURT
RICHARD E. & ELIZABETH S. NILSEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 17295-99, 17296-99. Filed July 3, 2001.
Jerome L. Blut, for petitioners.
Timothy S. Sinnott, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: In these consolidated
cases, 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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