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DIRKSE v. COMMISSIONER

Docket No. 13985-98.

80 T.C.M. 717 (2000)

T.C. Memo. 2000-356

Robert and Joyce Dirkse v. Commissioner.

United States Tax Court.

Filed November 15, 2000.

Attorney(s) appearing for the Case

Gerald W. Kelly, Jr., for the petitioners. Nicholas J. Richards, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined deficiencies and accuracy-related penalties under section 6662(a) with respect to petitioners' Federal income taxes, as follows:

                                      Penalty
Year                   Deficiency   Sec. 6662(a)

1995 ...............    $29,719        $5,944
1996 ...............     32,687         6,537

These deficiencies...

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