PORTER v. COMMISSIONER

Docket Nos. 19074-83, 36261-84.

51 T.C.M. 477 (1986)

T.C. Memo. 1986-70

Kenneth Porter v. Commissioner.

United States Tax Court.

Filed February 13, 1986.


Attorney(s) appearing for the Case

William T. Holloran, One Rockefeller Plaza, New York, N.Y., and Barbara T. Kaplan, for the petitioner. Frances Ferrito Regan, for the respondent.


Memorandum Findings of Facts and Opinion

NIMS, Judge:

Respondent determined the following deficiencies in and additions to petitioner's Federal income taxes:

                              Additions to Tax
                                            Sec. 6653(a)
  Year   Deficiency   Sec. 6653(b)1        (Alternatively)

  1979    $15,929       $ 7,965                 ...

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