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HOOPENGARNER v. COMMISSIONER

Docket No. 7896-00, 9423-01.

86 T.C.M. 723 (2003)

T.C. Memo. 2003-343

Herschel H. and Roberta S. Hoopengarner, v. Commissioner.

United States Tax Court.

Filed December 17, 2003.

Attorney(s) appearing for the Case

James G. LeBloch, for the petitioners.

Thomas J. Fernandez and Edwin Herrera, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined deficiencies in, additions to, and penalties on petitioners Herschel and Roberta Hoopengarner's (petitioners) income tax as follows:

                                         Accuracy-Related
                       Addition to Tax       Penalty
   Year   Deficiency   Sec. 6651(a)(1)     Sec. 6662(a)

   1994     $5,054           -0-                  $892
   1995...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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