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OPINION ........................... 592
Issue 37. Whether IRA Is Liable for the Section 6651(a)(1)
Addition to Tax for 1980 ................ 596
OPINION ........................... 596
Issue 38. Whether IRA Is Liable for the Section 6653(a)
Additions to Tax for 1980, and 1982 Through 1988 .... 597
OPINION ........................... 597
Issue 39. Whether IRA Is Liable for the Section 6659(a)
Additions to Tax for 1982 and 1983 ........... 601
OPINION ........................... 601
Issue 40. Whether IRA Is Liable for the Section 6661
Additions to Tax for 1983 Through 1988 ......... 602
OPINION ........................... 602
Issue 41. Whether IRA Is Liable for the Section 6662(a)
Accuracy-Related Penalty for 1989 ........... 606
OPINION ........................... 606
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: These consolidated cases were assigned to
Special Trial Judge D. Irvin Couvillion pursuant to Rules 180,
181, and 183.2 The Court agrees with and adopts the opinion of
the Special Trial Judge, which is set forth below.
2
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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