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DEIHL v. COMMISSIONER

Docket Nos. 11136-02, 16293-02, 1024-03.

90 T.C.M. 579 (2005)

T.C. Memo. 2005-287

Joseph A. and Sari F. Deihl v. Commissioner.

United States Tax Court.

December 15, 2005.

Attorney(s) appearing for the Case

Donald W. MacPherson and Bradley Scott MacPherson, for petitioners.

Jonae A. Harrison and J. Robert Cuatto, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge:

In these consolidated cases, respondent determined the following deficiencies and penalties with respect to petitioners' Federal income taxes:

   Year    Deficiency    Penalty Sec. 6662 I.R.C.

   1996   $1,364,714    $272,942.80
   1997   2,348,943     608,473.00
   1998   1,108,775     221,755.00

After concessions by the parties, the principal issues...

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