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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Last modified: November 10, 2007