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COHEN v. COMMISSIONER

Docket No. 9453-00.

85 T.C.M. 861 (2003)

T.C. Memo. 2003-42

Bradley M. Cohen and Kathy A. Cohen v. Commissioner.

United States Tax Court.

Filed February 24, 2003.

Attorney(s) appearing for the Case

Robert C. Keller, for the petitioners.

James N. Beyer, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge.

Respondent determined a deficiency of $20,556 in petitioners' Federal income tax for 1996. Respondent also determined an addition to tax of $3,718 under section 6651(a)(1) and a penalty of $3,505.20 under section 6662(a). Subsequently, through an amendment to answer, respondent asserted an increased deficiency of $135,120, addition to tax of $27,024, and penalty of $22,912.80. After concessions, the issues...

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