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BARRETT v. COMMISSIONER

Docket No. 12895-93.

71 T.C.M. 2863 (1996)

T.C. Memo. 1996-199

John T. Barrett, Jr. and Jane W.A. Barrett v. Commissioner.

United States Tax Court.

Filed April 24, 1996.

Attorney(s) appearing for the Case

William S. Barrett, for the petitioners. Carmino J. Santaniello, Jr., for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge:

Respondent determined deficiencies and penalties in petitioners' Federal income taxes as follows:

                               Penalty Pursuant to
Year              Deficiency     Section 6662(a)

1989 ..........    $ 3,800          $  760
1990 ..........     10,080           2,016

Unless otherwise indicated, all section references are to the Internal...

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