T.C. Memo. 2001-179
UNITED STATES TAX COURT
JESSE EMMIT AND MARJORIE A. RUPERT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11995-99. Filed July 19, 2001.
Joseph Onwuteaka, for petitioners.
Elaine H. Warren, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a $19,136 deficiency
and an accuracy-related penalty under section 6662(a)1 of $3,629
in petitioners’ 1996 Federal income tax. After agreements of the
parties, the issues presented for our consideration are: (1)
1 All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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