KADIVAR v. COMMISSIONER

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

In a notice of deficiency mailed to petitioner on October 9, 1985 respondent determined that petitioner is liable for excise taxes under section 4975 for the years and in amounts as follows:

                                 Section1
                             ------------------
Year                         4975(a)   4975(b)

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