CLAY v. COMMISSIONER

PUGH, Judge.

In notices of deficiency dated March 4, 2011, and January 10, 2013, respondent determined the following deficiencies and penalties:1

                               Penalty
    Year      Deficiency     sec. 6662(a)

    2004       $192,215        $38,443
    2005...

                    
                    

                        

                            

                                

                                    
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