William B. and Donna McDermott - Page 1

                                 T.C. Memo. 2003-269                                  

                               UNITED STATES TAX COURT                                

              WILLIAM B. MCDERMOTT AND DONNA MCDERMOTT, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18050-99.             Filed September 16, 2003.             

               William B. McDermott and Donna McDermott, pro sese.                    
               Stephen S. Ash, for respondent.                                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:  Petitioners petitioned the Court to                      
          redetermine a $215,493 deficiency in their 1995 Federal income              
          tax and a $43,099 accuracy-related penalty under section 6662(a).           
          Following respondent’s concession as to 17 of the 23 bank                   
          deposits determined by him in the notice of deficiency to be                
          income, and our granting of petitioners’ motion to dismiss much             

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