DRABIUK v. COMMISSIONER

Memorandum Findings of Fact and Opinion

LARO, Judge.

Stanislaw and Jeanette Drabiuk1 petitioned the Court for a redetermination of respondent's determination set forth in her notice of deficiency issued to them on March 17, 1994. Respondent determined deficiencies in petitioners' Federal income taxes, an addition to tax, and a penalty as follows:

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