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MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge: In separate notices of deficiency,
respondent determined the following income tax deficiencies,
penalties, and additions to tax with respect to petitioners’
Federal income tax returns:2
Henry and Esther Misle, Docket No. 14157-97
Penalty
Year Deficiency Sec. 6662(a)
1989 $19,906 $3,981
1990 106,768 21,354
1991 66,964 13,393
1992 25,733 5,147
1993 31,803 6,361
Henry and Esther Misle, Docket No. 16657-98
Penalty
Year Deficiency Sec. 6662(a)
1994 $67,902 $13,428
1996 71,900 14,380
Henry Misle, Docket No. 16658-98
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6654
1995 $62,797 $15,591 $3,422
2All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure. Monetary amounts are
rounded to the nearest dollar.
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Last modified: May 25, 2011