United States Tax Court December 16, 1998, Tax Ct. Dkt. No. 9126-96 (Fabry v. Commissioner)

lead-opinion

OPINION

Halpern, Judge:

I. Introduction

By notice of deficiency dated February 14, 1996, respondent determined a deficiency in petitioners’ 1992 Federal income tax of $201,054 and an accuracy-related penalty of $40,211.