T.C. Memo. 2007-320
UNITED STATES TAX COURT
ROBERT L. AND BRENDA J. TARTER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20688-05. Filed October 25, 2007.
Eric Johnson, for petitioners.
Christian A. Speck, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine respondent’s determination of a 2001 income tax
deficiency of $457,491, a section 6662(a)1 accuracy-related
1Rule references are to the Tax Court Rules of Practice and
Procedure. Unless otherwise noted, section references are to the
applicable versions of the Internal Revenue Code (Code).
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Last modified: November 10, 2007