Fumitake Nishi & Sachiyo Nishi v. Commissioner

T.C. Memo. 2019-143

UNITED STATES TAX COURT FUMITAKE NISHI AND SACHIYO NISHI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6936-17. Filed October 23, 2019. Eric William Johnson, for petitioners. Beth A. Nunnink, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION KERRIGAN, Judge: Respondent determined deficiencies in petitioners’ Federal income tax and section 6662(a) accuracy-related penalties for 2011, 2012, and 2013 (years in issue). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule…