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year 1990. In the notices, respondent determined deficiencies in
petitioner and Mr. Rowe’s Federal income taxes, additions to tax,
and penalties as follows:3
Additions to Tax and Penalties
Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661
1987 $173,817 $130,363 1 $43,454
Sec. 6653(b)(1) Sec. 6661
1988 53,937 $40,453 $13,484 --
Sec. 6651(a)(1) Sec. 6663
1989 73,279 $13,792 $54,959 --
Sec. 6654 Sec. 6662(c)
1990 124,891 $8,057 $24,978 --
150 percent of the interest due on $173,817.
Petitioner and Mr. Rowe timely filed petitions with this
Court on September 27, 1993, and November 18, 1994, respectively,
disputing all the determinations contained in the notices of
deficiency.4 No claim for relief from joint and several
liability was made in either of the petitions. Respondent filed
corresponding answers to the petitions on November 29, 1993, and
December 27, 1994, respectively, denying the allegations
contained in the petitions. The two cases were subsequently
consolidated for trial, briefing, and opinion.
3The fraud additions to tax pursuant to sec. 6653(b) for the
taxable years 1987 and 1988 and the fraud penalty pursuant to
sec. 6663 for the taxable year 1989 related only to Mr. Rowe.
4Petitioner resided in Florida at the time the petitions in
this case were filed.
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