HOOVER v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge.

These cases were consolidated for purposes of trial, briefing, and opinion. On August 20, 1999, respondent issued a notice of deficiency, which determined deficiencies and penalties with respect to petitioner's Federal income taxes as follows:

                               Penalty
Year         Deficiency       Sec. 6663

1989        $46,052       $34,539.00
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