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VERIHA v. COMMISSIONER

Docket No. 7099-10.

139 T.C. 45 (2012)

JOSEPH VERIHA AND CHRISTINA F. VERIHA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 8, 2012.

Attorney(s) appearing for the Case

Amy L. Barnes and Robert Edward Dallman, for petitioners.

Laurie B. Downs, for respondent.

OPINION

WELLS, Judge:

Respondent determined a deficiency in petitioners' 2005 Federal income tax of $258,785 and an accuracy-related penalty pursuant to section 6662(a) of $51,757.1 Respondent concedes that petitioners are not liable for the penalty. The issue we must decide is whether the income petitioner Joseph Veriha received from an S corporation in which he owned 99% of the...

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