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then decision should be entered for Sandra that she has no
deficiency and no addition to tax for any year in issue. By
amendment to answer, respondent asserts in the alternative to the
deficiencies and additions to tax determined in the notices of
deficiency that, if the Court determines that petitioners’
marriage contract has this effect and Sandra does not have any
liability, then Michael is liable for deficiencies and penalties
as follows:
Penalties
Year Deficiency Sec. 6663
1994 $8,966 $6,725
1995 30,872 23,154
See sec. 6214(a). Respondent also asserts, in the alternative to
section 6663, additions to tax under section 6662(a). See sec.
6214(a).
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