T.C. Memo. 2007-173 UNITED STATES TAX COURT TIMOTHY AND BARBARA KOSINSKI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9911-04. Filed July 2, 2007. Neal Nusholtz and Richard M. Lustig, for petitioners. Timothy S. Murphy, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Judge: Respondent determined a deficiency of $1,205,548 and an addition to tax for fraud pursuant to section 6663 of $904,161 with respect to petitioners’ Federal income tax for 1997. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, andPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007