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GERALD L. v. COMMISSIONER

Docket No. 8072-00.

83 T.C.M. 1632 (2002)

T.C. Memo. 2002-119

Gerald L. and Erma L. Dunnegan v. Commissioner.

United States Tax Court.

Filed May 14, 2002.

Attorney(s) appearing for the Case

David K. Holmes, for the petitioners.

Elizabeth Downs, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

Respondent determined deficiencies in petitioners' Federal income tax and penalties under section 6662(a) as follows:

                                                    Penalty, I.R.C.
  Year                                Deficiency      Sec. 6662(a)

  1993 ............................    $135,811       $ 2,815.80
  1994 ............................     ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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