MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge:
Respondent determined deficiencies of $21,670 and $23,054 in petitioner's income tax and accuracy-related penalties under section 6662(a) of $4,334 and $4,611, for the taxable years 1990 and 1991, respectively.
Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure....
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