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BROWNING v. COMMISSIONER OF INTERNAL REVENUE

No. 3531-08.

T.C. Memo. 2011-261

PERRY W. BROWNING, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 3, 2011.

Attorney(s) appearing for the Case

John M. Colvin and Robert J. Chicoine , for petitioner.

Carina J. Campobasso and Robert W. Dillard , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge.

By two notices of deficiency dated January 3, 2008 (the notices), respondent determined joint deficiencies in income taxes and related penalties for petitioner and his wife, Nancy L. Browning (Mrs. Browning), as follows:

Penalty Year Deficiency

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