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WILSON v. COMMISSIONER

Docket Nos. 18481-93, 17723-94.

72 T.C.M. 628 (1996)

T.C. Memo. 1996-418

Robert J. and Anne L. Wilson v. Commissioner.

United States Tax Court.

Filed September 17, 1996.

Attorney(s) appearing for the Case

Rex L. Sturm, for the petitioners. Michal Cline, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PARR, Judge:

Respondent determined deficiencies in, an addition to tax on, and penalties on petitioners' Federal income tax for taxable years 1989 and 1990 as follows:

                                                        Addition to Tax     Penalty
                                                        ---------------   ------------
Year                                       ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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