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ROBERT E. v. COMMISSIONER

Docket No. 12815-99.

85 T.C.M. 1438 (2003)

T.C. Memo. 2003-161

Robert E. and Yvonne R. Kovacevich v. Commissioner.

United States Tax Court.

Filed June 3, 2003.

Attorney(s) appearing for the Case

Robert E. Kovacevich and Richard W. Kochansky, for the petitioners.

Milton B. Blouke and Roger P. Law, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

By notice of deficiency dated April 28, 1999, respondent determined deficiencies, additions to tax, and penalties relating to petitioners' 1992 through 1994 Federal income tax returns as follows:

                    Addition to Tax   Penalty Sec.
Year   Deficiency     Sec. 6651(a)     6662(b)(1)

1992   18,232          1,330              3,176
...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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