Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $1,126 and $806 in petitioner's Federal income taxes for 1990 and 1991, respectively. Respondent also determined an accuracy-related penalty of $161 under section 6662(a) for 1991. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and...
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