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SELLERS v. COMMISSIONER

Docket No. 17064-97.

80 T.C.M. 135 (2000)

T.C. Memo. 2000-235

Philip A. Sellers and Estate of Caroline R. Sellers, Deceased, Philip A. Sellers, Executor v. Commissioner.

United States Tax Court.

Filed August 3, 2000.

Attorney(s) appearing for the Case

William B. Sellers, for the petitioners. Joseph Ineich, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

THORNTON, Judge:

Respondent determined deficiencies in petitioners' Federal income tax and accuracy-related penalties under section 6662 for taxable years 1993 and 1995 as follows:

                                        Penalty
Year                     Deficiency   Sec. 6662(a)

1993 .................     $49,843       $9,969
1995 .................       9,567        1,913...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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