T.C. Memo. 2003-321
UNITED STATES TAX COURT
RAFAEL M. GUTIERREZ AND ROSARIO GUTIERREZ, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11393-02. Filed November 20, 2003.
Jeffrey D. Moffatt, for petitioners.
Jean Song, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine a $43,812 deficiency in their 1998 Federal income tax
and an accuracy-related penalty of $8,762.40 under section
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