WARDEN v. COMMISSIONER

Memorandum Findings of Fact and Opinion

GALLOWAY, Special Trial Judge:

This case was heard pursuant to the provisions of section 7413A(b) and Rules 180, 181, and 182.1

In separate notices of deficiency for each taxable year dated February 21, 1989, respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:

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