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ARNOLD v. COMMISSIONER

Docket Nos. 13292-03, 13293-03, 1096-04.

90 T.C.M. 470 (2005)

T.C. Memo. 2005-256

Edward W. and Edith M. Arnold v. Commissioner.

United States Tax Court.

October 31, 2005.

Attorney(s) appearing for the Case

Edward W. Arnold and Edith M. Arnold,1 pro se.

Thomas J. Travers and Kelley A. Blaine, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined deficiencies in petitioners' income tax of $3,038 for 1999, $3,178 for 2000, and $27,549 for 2001 and accuracy-related penalties under section 6662(a) of $607.60 for 1999, $635.60 for 2000, and $69,217.40 for 2001.

After concessions,2 the issues for decision are:

1. Whether petitioners may deduct...

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