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ORTIZ v. COMMISSIONER

Docket No. 6202-95.

75 T.C.M. 2145 (1998)

T.C. Memo. 1998-141

Ramon and Irma Ortiz v. Commissioner.

United States Tax Court.

Filed April 16, 1998.

Attorney(s) appearing for the Case

Ramon Ortiz, pro se. Joanne B. Minsky, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WRIGHT, Judge:

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

                                          Penalties
Year                         Deficiency   Sec. 6663

1991 .....................    $15,459      $11,594
1992 .....................     32,657       24,493

In the alternative to the fraud penalties...

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