AUSTIN W. v. COMMISSIONER

Docket No. 8950-05.

92 T.C.M. 297 (2006)

T.C. Memo. 2006-205

Terri L. and Austin W. Hartsock, v. Commissioner.

United States Tax Court.

September 25, 2006.


Attorney(s) appearing for the Case

Stuart Levine, for petitioners;

Karen Lynne Baker, for respondent.

Stuart Levine, for petitioners.1


MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined deficiencies in, and accuracy-related penalties under section 6662(a)2 on, petitioners' Federal income tax (tax), as follows:

                           Accuracy-Related
Year       Deficiency      Penalty

1999       $87,099         $17,420
2000       104,225         20,845

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