Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined deficiencies in petitioner's Federal income tax liabilities for 1983, 1984, and 1985 in the respective amounts of $5,132, $12,908, and $13,794. Respondent did not determine any negligence additions to tax against petitioner. At trial, however, respondent moved for the award of damages to the United States and against petitioner under...
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