T.C. Memo. 2006-205
UNITED STATES TAX COURT
TERRI L. AND AUSTIN W. HARTSOCK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8950-05. Filed September 25, 2006.
Stuart Levine, for petitioners.1
Karen Lynne Baker, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined deficiencies in, and
accuracy-related penalties under section 6662(a)2 on, petition-
1Petitioners filed their petition with the Court and ap-
peared at trial pro sese. On Feb. 14, 2006, after the trial in
this case, Stuart Levine entered his appearance.
2All section references are to the Internal Revenue Code
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