Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for the year 1989 in the amount of $23,674 and for the year 1990 in the amount of $10,308. Respondent also determined accuracy-related penalties under section 6662(a) in the amounts of $1,470 and $2,061 for 1989 and 1990, respectively.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect...
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