Dennis L. Hayden and Sharon E. Hayden v. Commisioner of Internal Revenue

FLAUM, Circuit Judge.

Dennis and Sharon Hayden petitioned the United States Tax Court seeking a redetermination of the federal income tax deficiency and penalty assessed against them for the 1994 tax year. The Tax Court upheld the determinations and resulting addition to tax, and the Haydens now appeal. For the reasons stated herein, we affirm.

Background

During 1994, Dennis Hayden was self-employed as a certified public accountant and his wife, Sharon Hayden, was employed as a nurse. During that year, Dennis and Sharon Hayden were also the sole partners in a partnership known as Led-dos Frozen…