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CHIN v. COMMISSIONER

Docket No. 599-01.

85 T.C.M. 814 (2003)

T.C. Memo. 2003-30

Michael Chin and Julie Hedrich Chin v. Commissioner.

United States Tax Court.

Filed February 6, 2003.

Attorney(s) appearing for the Case

Robert F. Klueger, for the petitioners.

Michael W. Berwind, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined deficiencies in petitioners' Federal income tax and penalties for the taxable years 1994 and 1997 as follows:

                                                    Penalty
          Year                    Deficiency      Sec. 6662(h)

          1994 ..............       $22,319          ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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