T.C. Memo. 2001-148
UNITED STATES TAX COURT
CHARLES J. AND FRANCESCA C. SIGERSETH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18998-99. Filed June 21, 2001.
Charles J. and Francesca C. Sigerseth, pro sese.
Jeremy L. McPherson, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: Respondent determined deficiencies of
$384,998 and $445,463 in and section 6662(a) accuracy-related
penalties of $77,000 and $89,093 on petitioners’ 1995 and 1996
Federal income taxes, respectively.1 After having orally
1 Unless otherwise provided, section references are to the
Internal Revenue Code in effect for the years in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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