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BENDER v. COMMISSIONER

Docket No. 26641-81.

50 T.C.M. 538 (1985)

T.C. Memo. 1985-375

Daniel Bender v. Commissioner.

United States Tax Court.

Filed July 29, 1985.

Attorney(s) appearing for the Case

Woodford G. Rowland, for the petitioner (at trial). Jeffrey I. Margolis, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows:

                               Additions to Tax

Year       Deficiency    Sec. 6653(b)    Sec. 66541

1977...... $1,361,849      $680,925        $48,585

The deficiency resulted from respondent's determination that petitioner received income from...

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