CHRISTIANS v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

In a statutory notice of deficiency, mailed on May 4, 2001, respondent determined deficiencies in petitioner's Federal income tax and penalties for the taxable years 1992, 1993, and 1994 as follows:

                          Penalty
   Year    Deficiency    Sec. 6663

   1992    $ 4,831      $ 3,623.25
   1993     12,115        9,086.25
   1994     18,912...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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