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Janis v. Commissioner

Docket Nos. 14318-01, 1344-02.

87 T.C.M. 1322 (2004)

T.C. Memo. 2004-117

Conrad Janis and Maria G. Janis v. Commissioner. Carroll Janis and Donna L. Seldin Janis v. Commissioner.

United States Tax Court.

May 12, 2004.

Attorney(s) appearing for the Case

Andrew J. Wilson, Brian D. Caplan, and Vicki G. Cheikes, for petitioners in docket No. 14318-01.

Michael Schlesinger, for petitioners in docket No. 1344-02.

Lydia A. Branche and Shawna A. Early, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge.

Respondent determined deficiencies in petitioners Conrad Janis and Maria G. Janis's (Conrad and Maria) Federal income taxes for 1995, 1996, and 1997 and penalties under section 6662(a) for those years, respectively, as follows:


            Year     Deficiency            Sec. 6662(a) Penalty

            1995             ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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