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ROSENTHAL v. COMMISSIONER

Docket No. 2677-94.

70 T.C.M. 1614 (1995)

T.C. Memo. 1995-603

Raymond N. Rosenthal and Peggy S. Rosenthal v. Commissioner.

United States Tax Court.

Filed December 26, 1995.

Attorney(s) appearing for the Case

Raymond N. Rosenthal and Peggy S. Rosenthal, pro sese. Steven M. Roth, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

SCOTT, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes and accuracy-related penalties for the calendar years 1990 and 1991 as follows:

                                        Penalty
                                     -------------
Year                     Deficiency   Sec. 66621

1990 .................     $6...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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