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GEE v. COMMISSIONER

Docket No. 8755-05.

127 T.C. 1 (2006)

127 T.C. No. 1

CHARLOTTE AND CHARLES T. GEE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 24, 2006.

Attorney(s) appearing for the Case

Ed Daniel IV, for petitioners.

Caroline R. Krivacka, for respondent.

OPINION

KROUPA, Judge:

Respondent determined a $97,789 deficiency in petitioners' Federal income tax for 2002 and determined that petitioners are liable for the accuracy-related penalty under section 6662(a)1 for 2002.

There are two issues for decision. The first issue is whether a $977,888 distribution petitioner Charlotte Gee (petitioner) received in 2002 from an individual...

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