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JENKINS v. COMMISSIONER

Dkt. No. 10295-03.

91 T.C.M. 1015 (2006)

T.C. Memo. 2006-75

James E. Jenkins and Ruth A. Jenkins v. Commissioner.

United States Tax Court.

April 17, 2006.

Attorney(s) appearing for the Case

Thomas McKinney, Jr., for petitioners;

Martha J. Weber and Nancy Hale, for respondent.

Thomas McKinney, Jr., for petitioners.*

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

By notice of deficiency dated April 7, 2003, respondent determined deficiencies in and additions to petitioners' 1994, 1995, 1996, and 1997 Federal income taxes. The issues for decision are whether petitioners received unreported income and are liable for the section 6663(a)1 fraud penalty.

FINDINGS OF FACT

Petitioners married on April 14, 1990, and remained...

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