Zacharia and Rawa Hadri - Page 1

                                 T.C. Memo. 2002-77                                   

                               UNITED STATES TAX COURT                                

                    ZACHARIA HADRI AND RAWA HADRI, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4954-00.             Filed March 27, 2002.                  

               Zacharia Hadri and Rawa Hadri, pro sese.                               
               Kelley A. Blaine, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               GERBER, Judge:  Respondent determined a deficiency in income           
          tax and a fraud penalty for petitioners’ 1993 tax year as                   
                    Year      Deficiency     Sec. 6663(a)1                            
                   1993      $103,559       $77,668.50                               

               1 All section references are to the Internal Revenue Code as           
          amended and in effect for the year under consideration, and all             
          Rule references are to this Court’s Rules of Practice and                   
          Procedure, unless otherwise indicated.                                      

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