Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $5,221 and $4,600 in petitioner's Federal income taxes for 1990 and 1991, respectively. Respondent also determined additions to tax under section 6662(a) of $1,044 and $920 for those years, respectively. 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...
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