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MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: In these consolidated cases, respondent
determined the following deficiencies and additions to tax with
respect to petitioner’s Federal income taxes:
Additions to Tax
Year Deficiency Sec. 6651(a)1 Sec. 6654
1994 $ 15,345.00 $ 3,341.25 $ 682.09
1995 22,888.00 4,501.00 946.78
1996 128,008.00 30,519.50 6,462.58
1997 37,376.00 7,010.50 1,444.79
1998 40,669.00 7,175.00 1,252.40
1999 11,093.00 2,266.75 427.92
2000 11,662.00 2,306.00 478.24
2001 9,666.90 2,755.55 382.54
The parties stipulated petitioner’s filing status, number of
exemptions, gross income, allowable deductions, taxable income,
and in some instances allowable credits. After concessions by
the parties,2 the remaining issues for decision are:
(1) Whether respondent issued valid notices of deficiency
for the 1994 through 2001 taxable years;3
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) in effect for the years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
2 For all the years in issue, respondent conceded the sec.
72(t) tax and for 2001, the sec. 6651(a)(2) addition to tax. The
notices of deficiency for the taxable years 1994 through 2000 did
not indicate sec. 6651(a)(2) additions to tax.
3 Petitioner contends that the issue in this case is whether
the notices of deficiency were validly signed. The Court assumes
this is also an argument contesting the deficiency and additions
(continued...)
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