T.C. Memo. 2006-267 UNITED STATES TAX COURT NATHANIEL H. AND CAROL A. GARFIELD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4017-05. Filed December 18, 2006. Ronald J. Cohen and David S. Schwan, for petitioners. Frank J. Jackson and Karen A. Rennie, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION FOLEY, Judge: The issues for decision are whether income received by petitioners should be treated as ordinary income or long-term capital gain and whether petitioners are liable for the section 66621 accuracy-related penalty. 1 Unless otherwise indicated, all section references are to (continued...)Page: 1 2 3 4 5 6 7 8 Next
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