MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $29,178 for 1990 and $35,937 for 1991. Respondent also determined that petitioner is liable for an accuracy-related penalty for negligence under section 6662(c) of $5,836 for 1990 and $7,187 for 1991.
During the years in issue, petitioner deducted certain costs related to establishing public display gardens on her farm....
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