T.C. Memo. 2001-317
UNITED STATES TAX COURT
HERBERT L. WHITEHEAD AND JENNIFER L. WHITEHEAD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6271-00. Filed December 20, 2001.
J. Patrick Quinn, for petitioners.
Julie L. Payne, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined the following defi-
ciencies in, and accuracy-related penalties under section
6662(a)1 on, petitioners’ Federal income tax:
1Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) in effect for the years at
issue. All Rule references are to the Tax Court Rules of Prac-
tice and Procedure.
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