T.C. Memo. 1996-418
UNITED STATES TAX COURT
ROBERT J. AND ANNE L. WILSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 18481-93, 17723-94. Filed September 17, 1996.
Rex L. Sturm, for petitioners.
Michal Cline, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge: Respondent determined deficiencies in, an
addition to tax on, and penalties on petitioners’ Federal income
tax for taxable years 1989 and 1990 as follows:
Addition to Tax Penalty
Sec. Sec.
Year Deficiency 6651(a)(1) 6662(a)
1989 $28,496.00 -0- $5,699.00
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