MEMORANDUM OPINION
WELLS, Chief Judge:
In the case at Docket No. 7464-00, respondent determined deficiencies and penalties in income taxes as follows:
Liability of Donald R. Cooley Year Deficiency Sec. 6663(a) Penalties 1989 $2,982.63 $24,584.96 1990 2,617.74 28,705.73 1991 171.92 14,035.44...
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