T.C. Memo. 2006-110
UNITED STATES TAX COURT
ROBERT D. AND PATRICIA M. BRAUN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6348-04. Filed May 23, 2006.
Robert J. Gumser, for petitioners.
Sylvia L. Shaughnessy, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge: Respondent determined deficiencies in
petitioners' 1992 and 1993 Federal income tax of $4,293 and
$6,310, respectively, and additions to tax under section1
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986 as in effect for the taxable
years in issue.
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