T.C. Memo. 2000-76
UNITED STATES TAX COURT
SANDRA J. BRANNON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22025-97. Filed March 6, 2000.
J. Raymond Karam, for petitioner.
Elizabeth A. Owen, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: Respondent determined
deficiencies of $2,974 and $1,562 in Federal income taxes and
penalties under section 6662(a)1 of $595 and $312, respectively,
for petitioner's 1993 and 1994 tax years.
1 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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