T.C. Memo. 2003-64
UNITED STATES TAX COURT
ED AND PATRICIA A. MONTGOMERY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1816-00. Filed March 5, 2003.
David H. McQuaig, for petitioner.
Felicia L. Branch, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: Respondent determined
deficiencies in petitioners’ Federal income taxes of $2,975 and
$3,537, and accuracy-related penalties of $595 and $707.40, for
the taxable years 1996 and 1997. By amended answer, respondent
pled increased deficiencies and penalties for each year in issue,
for deficiencies totaling $5,355 and $6,351, and penalties
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