T.C. Memo. 2003-42
UNITED STATES TAX COURT
BRADLEY M. COHEN AND KATHY A. COHEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9453-00. Filed February 24, 2003.
Robert C. Keller, for petitioners.
James N. Beyer, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of $20,556
in petitioners’ Federal income tax for 1996. Respondent also
determined an addition to tax of $3,718 under section 6651(a)(1)
and a penalty of $3,505.20 under section 6662(a). Subsequently,
through an amendment to answer, respondent asserted an increased
deficiency of $135,120, addition to tax of $27,024, and penalty
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