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SMITH v. COMMISSIONER

Dkt. Nos. 11902-05, 13225-05, 13226-05, 13227-05, 13228-05.

94 T.C.M. 574 (2007)

T.C. Memo. 2007-368

Rhett Rance Smith and Alice Avila Smith, et al. v. Commissioner.

United States Tax Court.

December 17, 2007.

Attorney(s) appearing for the Case

Robert J. Stientjes, Thomas C. Pliske, Shine Lin, and Anthony S. Gasaway, for petitioners.

Anne W. Durning, Nicholas J. Richards, Laura Beth Salant, and Chris J. Sheldon, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined the following income tax deficiencies and penalties with respect to petitioners in these consolidated cases:

                                                          Accuracy-Related Penalty
                Petitioners          Year   Deficiency                   Sec. 6662

Rhett...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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