Memorandum Findings of Fact and Opinion
LARO, Judge:
Dennis E. Sproul petitioned the Court for a redetermination of respondent's determinations set forth in two notices of deficiency issued on March 19, 1991, and November 9, 1992. On July 14, 1993, the Court granted respondent's motion to consolidate these cases for purposes of trial, briefing, and opinion. Respondent determined deficiencies in petitioner's Federal income taxes, an addition to tax, and penalties...
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