T.C. Memo. 2001-280
UNITED STATES TAX COURT
CHARLES E. AND JACQUELYN YATES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 5386-00, 8504-00. Filed October 11, 2001.
Bruce M. Reynolds and Ashley W. Ward, for petitioners.
Michael D. Zima, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notices dated February 9 and June 23,
2000, respondent determined deficiencies in petitioners’ 1994,
1995, and 1996 Federal income taxes of $237,945, $457,955, and
$172,586, respectively. All section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
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