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CHRISTIANS v. COMMISSIONER

Docket No. 9814-01.

85 T.C.M. 1267 (2003)

T.C. Memo. 2003-130

Kyl Christians v. Commissioner.

United States Tax Court.

Filed May 5, 2003.

Attorney(s) appearing for the Case

Ted E. Merriam and Kevin A. Planegger, for the petitioner.

Richard D. D'Estrada and Frederick J. Lockhart, Jr., for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

In a statutory notice of deficiency, mailed on May 4, 2001, respondent determined deficiencies in petitioner's Federal income tax and penalties for the taxable years 1992, 1993, and 1994 as follows:

                          Penalty
   Year    Deficiency    Sec. 6663

   1992    $ 4,831      $ 3,623.25
   1993     12,115        9,086.25
   1994     18,912...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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