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PATERSON v. COMMISSIONER

Dkt Nos. 8093-04, 8094-04, 22397-04.

93 T.C.M. 1184 (2007)

T.C. Memo. 2007-109

Patricia B. Paterson, et al. v. Commissioner.

United States Tax Court.

April 30, 2007.

Attorney(s) appearing for the Case

Thomas Edward Brever, for petitioners.

David W. Sorenson and Lisa R. Woods, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KROUPA, Judge.

Respondent determined deficiencies in petitioners' Federal income taxes and fraud penalties under section 6663 for 1997 and 1998 (the years at issue).2

Respondent determined that petitioner Patricia B. Paterson (Mrs. Paterson) was liable for a $53,168 deficiency and a $39,876 fraud penalty for 1997. For 1998, respondent determined that Mrs. Paterson was liable for...

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