Memorandum Findings of Fact and Opinion
Laro, Judge:
This case is before the Court pursuant to a petition filed by Danny J. Jackson and Sue C. Jackson (petitioners) for redetermination of respondent's determination of deficiencies in, and penalties on, their 1989 and 1990 Federal income taxes. Respondent's determination is reflected in a notice of deficiency that respondent issued to petitioners on February 9, 1993. The notice provides, in part, that petitioners...
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