KEESE v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

CARLUZZO, Special Trial Judge:

These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1

In separate notices of deficiency, respondent determined deficiencies in petitioner's 1991 and 1992 Federal income taxes, an addition to tax, and penalties as follows:

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