United States Tax Court September 21, 1994, Docket No. 17765-92 (Waterhouse v. Commissioner)

CHARLES H. AND BARBARA WATERHOUSE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Waterhouse v. Commissioner Docket No. 17765-92 United States Tax Court T.C. Memo 1994-467; 1994 Tax Ct. Memo LEXIS 475; 68 T.C.M. (CCH) 744; September 21, 1994, Filed *475 Decision will be entered for respondent as to the deficiency and for petitioners as to the penalty under sec. 6662, I.R.C.