T.C. Memo. 1997-416
UNITED STATES TAX COURT
NICHOLAS A. AND MARJORIE E. PALEVEDA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 840-96. Filed September 18, 1997.
Nicholas A. Paleveda, for petitioners.
Clinton M. Fried, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge: Respondent determined deficiencies in
petitioners' Federal income tax and additions to tax and
accuracy-related penalties for the taxable years 1990 and 1991 as
follows:
Additions Accuracy-Related
to Tax Penalties
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1990 $45,861 $11,465 $9,172
1991 47,688 11,922 9,538
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