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KELLER v. COMMISSIONER

Dkt. No. 9662-01.

91 T.C.M. 1292 (2006)

T.C. Memo. 2006-131

Michael W. Keller v. Commissioner.

United States Tax Court.

June 22, 2006.

Attorney(s) appearing for the Case

Asher B. Bearman, Jaret R. Coles, Jennifer A. Gellner, Terri A. Merriam, and Wendy S. Pearson, for petitioner.

Catherine J. Caballero, Gregory M. Hahn, Nhi T. Luu-Sanders, and Thomas N. Tomashek, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge.

Respondent determined deficiencies in petitioner's Federal income taxes of $11,106 and $17,410 for 1994 and 1995, respectively. Respondent further determined that petitioner was liable for accuracy-related penalties under section 6662(h) of $4,442 and $6,932, respectively.1 After concessions,2

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