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SERGEANT v. COMMISSIONER

Docket No. 13646-96.

76 T.C.M. 133 (1998)

T.C. Memo. 1998-265

Barry John Sergeant and Christine M. Sergeant v. Commissioner.

United States Tax Court.

Filed July 20, 1998.

Attorney(s) appearing for the Case

Barry John Sergeant and Christine M. Sergeant, pro sese. Michael P. Breton, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined the following deficiencies in, and penalty on, petitioners' Federal income taxes:

                                          Penalty
Year                        Deficiency   Sec. 6662

1993 ...................     $  2,852        --
1994 ...................       10,402      $2,080

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