T.C. Memo. 2002-199 UNITED STATES TAX COURT ROBERT M. AND NANCY I. STEWART, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 365-01. Filed August 8, 2002. Martin Brant Fenster, for petitioners. Matthew A. Mendizabal, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION RUWE, Judge: Respondent determined deficiencies of $35,106 and $36,999 in petitioners’ Federal income taxes, and accuracy- related penalties under section 6662(a)1 of $6,753 and $7,400, 1All section references are to the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 Next
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