T.C. Memo. 2004-82
UNITED STATES TAX COURT
NICK KIKALOS AND HELEN KIKALOS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11486-01. Filed March 23, 2004.
John J. Morrison, for petitioners.
Ronald T. Jordan, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a deficiency in
petitioners’ Federal income tax for the taxable year 1997 of
$105,296 and a penalty under section 6662(a)1 in the amount of
1 All section references are to the Internal Revenue Code in
effect for the year at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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