T.C. Memo. 2006-235 UNITED STATES TAX COURT JORGE O. AND CLELIA E. SVOBODA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13195-04. Filed November 2, 2006. Jorge O. and Clelia E. Svoboda, pro sese. Karen Nicholson Sommers, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GALE, Judge: Respondent determined an income tax deficiency and an accuracy-related penalty under section 6662(a)1 with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986 as in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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