MEMORANDUM FINDINGS OF FACT AND OPINION1
MARVEL, Judge.
In separate notices of deficiency, respondent determined the following income tax deficiencies and penalties with respect to petitioners' Federal income taxes:
Greg William Gouveia, a.k.a. Greg W. Gouveia, a.k.a. Greg Gouveia and Carol Ann Gouveia, a.k.a. Carol Gouveia, docket No. 288-03 ...
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