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SHEDD v. COMMISSIONER

Docket Nos. 3209-99, 3210-99.

80 T.C.M. 383 (2000)

T.C. Memo. 2000-292

J. Michael Shedd and Marita Shedd v. Commissioner. J&J Management Group, Inc. v. Commissioner.

United States Tax Court.

Filed September 18, 2000.

Attorney(s) appearing for the Case

Marc A. Letvin, for the petitioners. Gary R. Shuler, Jr. and Matthew J. Fritz, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

These consolidated cases involve income tax deficiencies determined by respondent for petitioners' 1994 and 1995 taxable years. Respondent determined income tax deficiencies and penalties for petitioners J. Michael and Marita Shedd, Docket No. 3209-99, as follows:

                                                                           Penalty

Year                     ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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