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DAGRES v. COMMISSIONER

Docket No. 15523-08.

136 T.C. 263 (2011)

TODD A. AND CAROLYN D. DAGRES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 28, 2011.

Attorney(s) appearing for the Case

Joel R. Carpenter, David J. Nagle, and Barry S. Pollack, for petitioners.

Carina J. Campobasso, for respondent.

GUSTAFSON, Judge:

On March 21, 2008, the Internal Revenue Service (IRS) issued to petitioners Todd and Carolyn Dagres1 a notice of deficiency pursuant to section 6212,2 determining a deficiency of $981,980 in income tax for 2003 and an accompanying accuracy-related penalty of $196,369 under section 6662(a). After Mr. Dagres's concession that the $30,000 of interest...

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