MEERSMAN v. COMMISSIONER

Memorandum Findings of Fact and Opinion

PANUTHOS, Chief Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181 and 182.1

Respondent determined deficiencies and penalties in petitioner's Federal income tax for the taxable years 1989 and 1990 as follows:

                                         Penalty
Year                      Deficiency   Sec. 6662...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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