T.C. Memo. 2006-156
UNITED STATES TAX COURT
RONALD A. AND CAROL J. LEHRER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2381-04. Filed July 31, 2006.
John Gigounas and Edward B. Simpson, for petitioners.
Margaret A. Martin, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge: Respondent determined deficiencies in
petitioners’ Federal income tax and accuracy-related penalties
under section 6662(a)1 for 1999, 2000, and 2001 (the years at
1All section references are to the Internal Revenue Code
(Code) for the years at issue, and all Rule references are to the
(continued...)
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