T.C. Memo. 2002-40
UNITED STATES TAX COURT
CAPITAL VIDEO CORPORATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
KENNETH GUARINO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 4094-00, 4096-00. Filed February 11, 2002.
James P. Redding and Brian C. Newberry, for petitioners.
Michael P. Breton, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: These cases are consolidated for trial,
briefing, and opinion. Respondent determined deficiencies in
petitioners’ Federal income taxes and accuracy-related penalties
as follows:
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