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 (thePage: 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007