MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge.
By two notices of deficiency dated January 3, 2008 (the notices), respondent determined joint deficiencies in income taxes and related penalties for petitioner and his wife, Nancy L. Browning (Mrs. Browning), as follows:
Let's get started

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.