SCHROEDER, Chief Judge:
Taxpayers, Charles Y. Choi and his wife Jin Yi Choi, appeal the Tax Court's determination that they underreported the income from their Arizona grocery store on their 1991 and 1992 federal tax returns and the imposition of a civil fraud penalty under 26 U.S.C. § 6663. It is undisputed that the Chois did not maintain adequate records for the store and that the Commissioner therefore was entitled to use an indirect method of reconstructing...
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