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HAGHNAZARZADEH v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 27031-17.

T.C. Memo. 2021-47

JOSEF HAGHNAZARZADEH AND CATHERINE Y. HAGHNAZARZADEH, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed April 29, 2021.

Attorney(s) appearing for the Case

Josef Haghnazarzadeh and Catherine Y. Haghnazarzadeh, pro sese.

Halvor R. Melom, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

Respondent determined deficiencies of $2,020,083 and $960,655 and penalties pursuant to section 6662(a) of $404,017 and $192,131 for 2011 and 2012 (years at issue), respectively. The parties have filed two stipulations of settled issues,1 and the only...

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