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KNOLL v. COMMISSIONER

Docket Nos. 10973-99, 5281-00.

86 T.C.M. 396 (2003)

T.C. Memo. 2003-277

Edward P. Knoll and Mary K. King-Knoll v. Commissioner.

United States Tax Court.

Filed September 23, 2003.

Attorney(s) appearing for the Case

Robert J. Paley and Scott A. Carlson, for the petitioners.

Sean R. Gannon, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined deficiencies in petitioners' Federal income tax and penalties for the taxable years 1993, 1994, and 1995, as follows:

                                 Penalty
  Year       Deficiency         Sec. 6662

  1993        $18,873            $3,775
  1994         47,756             9,551
  1995      ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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