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Kamil v. Commissioner

Docket Nos. 8094-02, 8095-02.

87 T.C.M. 1435 (2004)

T.C. Memo. 2004-154

Kamil F. and Nagwa Gowni v. Commissioner. George R. and Nehad Mansour v. Commissioner.

United States Tax Court.

June 29, 2004.

Attorney(s) appearing for the Case

Peter C. Pappas, for petitioners.

Stephen R. Takeuchi, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge.

Respondent determined deficiencies, an addition to tax, and penalties with respect to petitioners Kamil F. and Nagwa Gowni's (the Gownis) Federal income taxes for 1998 and 1999 as follows:

                      Addition to Tax      Penalty
  Year    Deficiency    Sec. 6651(a)(1)    Sec. 6662(a)
  1998    $105,470             --            $21,094...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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