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PAU v. COMMISSIONER

Docket No. 20475-94.

73 T.C.M. 1819 (1997)

T.C. Memo. 1997-43

Peter S. Pau and Susanna H. Pau v. Commissioner.

United States Tax Court.

Filed January 27, 1997.

Attorney(s) appearing for the Case

John M. Youngquist, San Francisco, Calif., for the petitioners. Patricia Anne Golembiewski, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PARR, Judge:

Respondent determined a deficiency in and a penalty on petitioners' 1990 Federal income tax as follows:

                                       Panalty
Year                    Deficiency   Sec. 6662(a)

1990 ................    $438,692      $61,040

On November 7, 1994, the Paus filed a petition with this Court. An answer was filed on December 20, 1994...

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