T.C. Memo. 2007-369
UNITED STATES TAX COURT
J. RAMSAY FARAH AND ELIZABETH FARAH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23412-05. Filed December 19, 2007.
Jurist Bruce Howard, for petitioners.
Jay A. Roberts and Ann M. Welhaf, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge: Respondent determined a deficiency in
petitioners’ Federal income tax of $170,925 and a penalty under
section 6662(a) of $34,185, for 2001.1
1Unless otherwise indicated, section references are to the
Internal Revenue Code, as amended. Rule references are to the
Tax Court Rules of Practice and Procedure. Amounts are rounded
to the nearest dollar.
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