EDDIE M. v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

ARMEN, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1

Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1989 and 1990, as well as an addition to tax and a penalty, as follows:

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