Alex and Tonja Oria - Page 1
















                                 T.C. Memo. 2007-226                                  


                               UNITED STATES TAX COURT                                


                         ALEX AND TONJA ORIA, Petitioners v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 246-05.                Filed August 14, 2007.               


               Steve M. Williard, for petitioners.                                    
               Richard T. Cummings, for respondent.                                   


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               HALPERN, Judge:  Respondent has determined deficiencies of             
          $191,651 and $550,914 in petitioners’ 1999 and 2000 Federal                 
          income taxes, respectively, and accuracy-related penalties of               
          $38,330.20 and $110,182.80 for those years, respectively.  The              
          parties have filed a stipulation of settled issues (the                     







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