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PALEVEDA v. COMMISSIONER

Docket No. 840-96.

74 T.C.M. 610 (1997)

T.C. Memo. 1997-416

Nicholas A. and Marjorie E. Paleveda v. Commissioner.

United States Tax Court.

Filed September 18, 1997.

Attorney(s) appearing for the Case

Nicholas A. Paleveda, for the petitioners. Clinton M. Fried, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge:

Respondent determined deficiencies in petitioners' Federal income tax and additions to tax and accuracy-related penalties for the taxable years 1990 and 1991 as follows:

                                                         Additions to     Accuracy-Related
                                                              Tax             Penalties
Year ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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