Memorandum Opinion
Couvillion, Special Trial Judge:
These consolidated cases were heard pursuant to section 7443A(b)(3)
Respondent determined, for petitioner's 1989 and 1990 tax years, respectively, deficiencies in Federal income taxes of $2,418 and $4,823, and penalties under section 6662(a), for negligence or disregard of rules or regulations under section 6662(b)(1), of $483.60 and $964...
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