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ROBERT L. v. COMMISSIONER

Dkt. No. 20688-05.

94 T.C.M. 408 (2007)

T.C. Memo. 2007-320

Robert L. and Brenda J. Tarter v. Commissioner.

United States Tax Court.

October 25, 2007.

Attorney(s) appearing for the Case

Eric Johnson, for petitioners.

Christian A. Speck, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge.

Petitioners petitioned the Court to redetermine respondent's determination of a 2001 income tax deficiency of $457,491, a section 6662(a)1 accuracy-related penalty of $91,498.20, and a section 6651(a)(1) addition to tax of $22,693.10 for failure to file timely. With regard to the income tax deficiency, we decide whether petitioners' claimed trade or business expense deductions...

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