Charles J. and Francesca C. Sigerseth - Page 1

                                 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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