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ROTHNER v. COMMISSIONER

Docket No. 26134-93.

72 T.C.M. 801 (1996)

T.C. Memo. 1996-442

David Rothner and Nancy J. Rothner v. Commissioner.

United States Tax Court.

Filed September 26, 1996.

Attorney(s) appearing for the Case

Francis J. Emmons, Chicago, Ill., for the petitioners. Joseph Ferrick, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge:

Respondent determined deficiencies in, and penalties on, petitioner David Rothner's (petitioner) Federal income taxes as follows:

                                         Penalty
Year                      Deficiency   Sec. 6662(a)

1989 ..................    $246,497      $49,299
1990 ..................      88,759       17,752

Respondent also determined...

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