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MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge: Respondent determined deficiencies in
petitioners' Federal income taxes, an addition to tax, and
penalties as follows:2
Jane Crocker, docket No. 11020-94, and Justin M. Jacobs, Jr.,
docket No. 11985-94:
Addition to Tax Penalty
Year Deficiency Sec. 6653(a)(1) Sec. 6662(a)
1988 $152,905 $7,645
1989 187,343 $37,469
Jane Crocker, docket No. 11022-94:
Penalty
Year Deficiency Sec. 6662(a)
1990 $8,621 $1,724
1991 26,842 5,368
Justin M. Jacobs, Jr., docket No. 11986-94:
Penalty
Year Deficiency Sec. 6662(a)
1990 $395,134 $79,027
2 Respondent issued one notice of deficiency for taxable
years 1988 and 1989 to petitioners, each of whom filed a separate
petition with the Court. Respondent also issued separate notices
of deficiency, one to petitioner Justin M. Jacobs, Jr., for the
year 1990, and the other to petitioner Jane Crocker for the years
1990 and 1991. Each petitioner filed a separate petition with
the Court with respect to these notices.
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