T.C. Memo. 2006-162
UNITED STATES TAX COURT
ROBERT C. AND GAIL K. RACINE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17633-04. Filed August 14, 2006.
Don Paul Badgley and Brian Gary Isaacson, for petitioners.
Kirk M. Paxson and William C. Schmidt, for respondent.
MEMORANDUM OPINION
GOEKE, Judge: Respondent determined a $514,462 deficiency
in petitioners’ Federal income tax and determined that
petitioners are liable for a $102,892.40 accuracy-related penalty
under section 6662(a)1 for 2000. We are asked to decide whether
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.
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