T.C. Memo. 2006-111
UNITED STATES TAX COURT
JEAN-REMY FACQ AND JENNIFER HUFF-FACQ, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2757-05. Filed May 23, 2006.
Don Paul Badgley and Brian Gary Isaacson, for petitioners.
Kirk M. Paxson and William C. Schmidt, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge: Respondent determined a $6,706,234
deficiency in petitioners’ Federal income taxes and determined
that petitioners were liable for a $1,341,246.80 accuracy-related
penalty under section 6662(a)1 for 2000.2 We are asked to
1All 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.
2Respondent also determined a $73,512 deficiency and
(continued...)
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011