KENCO RESTAURANTS, INC. v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge:

These cases have been consolidated for trial, briefing, and opinion. Respondent has determined deficiencies in income tax and accuracy-related penalties as follows:

Petitioner                                                Year   Deficiency   Penalty

Kenco Restaurants, Inc. (Kenco) .......................   1990     $36,664     $7,333
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