T.C. Memo. 2005-248
UNITED STATES TAX COURT
DENNIS L. ROGERS AND CHARLOTTE ROGERS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13428-02. Filed October 26, 2005.
Dana R. Taylor, for petitioners.
Kelley A. Blaine and Robert V. Boeshaar, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioners’ income tax of $186,536 for 1997 and $269,225 for
1998 and that petitioners are liable for the addition to tax for
late filing under section 6651(a)(1)1 of $45,384 for 1997 and
1 Unless otherwise stated, section references are to the
(continued...)
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