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FACQ v. COMMISSIONER

Dkt. No. 2757-05.

91 T.C.M. 1201 (2006)

T.C. Memo. 2006-111

Jean-Remy Facq and Jennifer Huff-Facq v. Commissioner.

United States Tax Court.

May 23, 2006.

Attorney(s) appearing for the Case

Don Paul Badgley and Brian Gary Isaacson, for petitioners;

Kirk M. Paxson and William C. Schmidt, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KROUPA, Judge:

Respondent determined a $6,706,234 deficiency in petitioners' Federal income taxes and determined that petitioners were liable for a $1,341,246.80 accuracy-related penalty under section 6662(a)1 for 2000.2 We are asked to decide, after concessions,3 whether petitioners received income in 2000 when petitioner Jean-Remy...

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