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PEREZ v. COMMISSIONER

Docket Nos. 39954-84, 28957-85.

56 T.C.M. 312 (1988)

T.C. Memo. 1988-464

Santiago Perez v. Commissioner.

United States Tax Court.

Filed September 26, 1988.

Attorney(s) appearing for the Case

Richard H. Bergman, 18204 Biscayne Blvd., N. Miami Beach, Fla., for the petitioner. Sergio Garcia-Pages, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent, in a statutory notice of deficiency dated July 9, 1984,1 determined deficiencies and additions to tax for the taxable years 1983 and 1984,2 respectively, as follows:

                                                       Additions to Tax
                                    --------------------------------------...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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