PEARSON v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge:

Respondent determined deficiencies in, and additions to, petitioner's Federal income tax for taxable years 1999 through 2003 as follows:

                                           Additions to Tax
                                  Sec.          Sec.          Sec.
     Year       Deficiency      6651(f)      6651(a)(2)      6654

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