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SWAIN v. COMMISSIONER

Docket No. 16556-94.

71 T.C.M. 1846 (1996)

T.C. Memo. 1996-22

Abhimanyu Swain v. Commissioner.

United States Tax Court.

Filed January 23, 1996.

Attorney(s) appearing for the Case

Abhimanyu Swain, pro se. Helen F. Rogers, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PANUTHOS, Chief Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioner's 1989 and 1990 Federal income taxes in the amounts of $2,092 and $2,190, respectively, and penalties pursuant to section 6662(a) in the amounts of $399 and $438, respectively. After concessions,

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