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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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