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JANICE v. COMMISSIONER

Docket No. 18377-04.

92 T.C.M. 250 (2006)

T.C. Memo. 2006-191

Thomas and Janice Gleason, v. Commissioner.

United States Tax Court.

September 11, 2006.

Attorney(s) appearing for the Case

Thomas and Janice Gleason, pro sese.

John W. Stevens, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge:

Respondent determined the following deficiencies and penalties with respect to petitioners' Federal income taxes:

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

   1994     $18,583                        $3,717
   1995     663,679                       132,736

After concessions, the principal issues for decision are:

(1) Whether petitioners...

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