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HERBERG v. COMMISSIONER

Docket No. 22957-81.

53 T.C.M. 755 (1987)

T.C. Memo. 1987-229

James P. Herberg v. Commissioner.

United States Tax Court.

Filed May 4, 1987.

Attorney(s) appearing for the Case

James P. Herberg, pro se. Thomas E. Crowe, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined deficiencies in and additions to petitioner's income taxes as follows:

                                 Additions to Tax
  Year             Deficiency    Section 6653(b)1

  1977 .......... $241,592.07      $120,796.03
  1978 .......... $220,267.05      $110,133.52

The issues are: (1) whether petitioner...

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