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SNYDER v. COMMISSIONER

Docket No. 5950-82.

86 T.C. 567 (1986)

RICHARD T. SNYDER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 2, 1986.

Attorney(s) appearing for the Case

Ralph S. Boggs, for the petitioner.

Fera Wagner, for the respondent.

COHEN, Judge:

Respondent determined deficiencies of $12,855 and $28,482.51 in petitioner's Federal income taxes for 1978 and 1979, respectively, and additions to tax under section 6653(a)1 of $642.75 and $1,424.13, respectively, for those years. By amendment to the answer, respondent seeks additional interest under section 6621(d) on the ground that the deficiency for the year 1979 is attributable to a valuation overstatement within...

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