T.C. Memo. 2003-10
UNITED STATES TAX COURT
DENNIS J. AND CAROL R. KRAUS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2009-01. Filed January 9, 2003.
Dennis J. and Carol R. Kraus, pro sese.
Michael W. Berwind, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined deficiencies in
petitioners’ 1997 and 1998 income tax of $10,069 and $10,337,
respectively. Respondent also determined penalties under section
6662(a)1 for 1997 and 1998 of $4,027.60 and $4,134.80,
1 All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
(continued...)
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