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decision to be entered is not reviewable by any other court, and
this opinion should not be cited as authority.
In a notice of deficiency mailed on April 13, 2001,
respondent determined deficiencies in petitioner’s Federal income
taxes and imposed penalties as follows:
Year Deficiency Sec. 6662 Penalty Sec. 6663 Penalty
1993 $9,177 --- $6,882.75
1994 5,701 $1,140.20 4,275.75
1995 4,172 834.40 3,129.00
Different amounts are asserted in respondent’s amended
answer. After discovery of unspecified errors in the
calculations of those amounts, the parties agree that, as
properly computed, the deficiencies and penalties here in dispute
are as follows:
Year Deficiency Sec. 6662 Penalty Sec. 6663 Penalty
1993 $6,952 --- $5,214.00
1994 6,147 $1,282.00 4,808.00
1995 6,824 2,103.00 7,887.00
The issues for decision are: (1) Whether petitioner
underreported his income during each year in issue; and, if so,
(2) whether the underpayment of tax required to be shown on
petitioner’s return for each year is due to fraud or, for 1994
and 1995, as an alternative to fraud, whether the underpayment of
tax required to be shown on petitioner’s return is due to
negligence.
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