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MACIEL v. COMMISSIONER

Docket No. 7802-00.

87 T.C.M. 881 (2004)

T.C. Memo. 2004-28

George Maciel v. Commissioner.

United States Tax Court.

Filed February 4, 2004.

Attorney(s) appearing for the Case

David M. Kirsch, for the petitioner.

G. Michelle Ferreira and Charlotte A. Mitchell, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge.

Respondent determined deficiencies in petitioner's Federal income taxes and penalties pursuant to section 66631 as follows:

    Year            Deficiency     Penalty Sec. 6663

    19901      $192,954          $144,715.50
    1991              71,337            53...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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