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PRIETO v. COMMISSIONER

Docket No. 12606-99.

82 T.C.M. 716 (2001)

T.C. Memo. 2001-266

Victor A. and Marion W. Prieto v. Commissioner.

United States Tax Court.

Filed October 4, 2001.

Attorney(s) appearing for the Case

Gregg M. Anderson and Richard W. Craigo, for the petitioners. Peter C. Rock, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined the following deficiencies in and penalties on petitioners' Federal income tax:

                                                Penalties
Year                           Deficiencies   Sec. 6662(a)

1994 ........................    $155,045       $31,009
1995 ........................     152,790        30,558

All section references...

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