MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies of $9,104 and $32,949 in petitioner's Federal income taxes for 1997 and 1998, respectively, and penalties of $1,821 and $6,590 under section 6662(b)(1) or, in the alternative, section 6662(b)(2), for those years, respectively. The issues for decision are: (1) Whether petitioner reported the correct amount of gain resulting from the sale of her interest in a parcel of...
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