MEMORANDUM OPINION
PARR, Judge:
Respondent determined deficiencies of $17,822 and $14,506 in petitioner's Federal income taxes for the taxable years ending June 30, 1994, and June 30, 1995, respectively, and an accuracy-related penalty of $3,564 under section 6662(a) for 1994.
All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure...
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