Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $6,484 and $8,949 in petitioner's Federal income tax for 1989 and 1990, respectively. Respondent also determined fraud penalties under section 6663 in the amounts of $4,863 and $6,712 for 1989 and 1990, respectively. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to...
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