SINE v. COMMISSIONER

Memorandum Opinion

SWIFT, Judge:

This matter is before the Court on respondent's motion for summary judgment. In a timely notice of deficiency dated March 19, 1986, respondent determined deficiencies in petitioner George F. Sine's Federal income tax and additions to tax for the years and in the amounts set forth below:

                                         Additions to Tax, I.R.C. Sec.1
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