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O'NEAL v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 3648-10.

T.C. Memo. 2016-49

JAMES T. O'NEAL, JR., AND SALLY L. O'NEAL, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 14, 2016.

Attorney(s) appearing for the Case

James T. O'Neal, Jr., and Sally L. O'Neal, pro se.

Laura A. Price , Mark J. Tober , and Lauren B. Epstein , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

By notice of deficiency dated November 6, 2009, respondent determined deficiencies and penalties with respect to petitioners' Federal income tax as follows:1

Penalty ...

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