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RITCHIE v. COMMISSIONER

Docket No. 35179-87.

57 T.C.M. 1282 (1989)

T.C. Memo. 1989-426

Clarence R. Ritchie v. COMMISSIONER.

United States Tax Court.

Filed August 15, 1989.

Attorney(s) appearing for the Case

Wayne Toliver, for the petitioner.

Abbey B. Garber, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge.

Respondent determined a deficiency in petitioner's Federal income tax for the calendar year 1983 in the amount of $28,691.50 and an addition to tax under section 6651(a)(1) for that year in the amount of $3,172.87.1 The issues for decision are: (1) whether petitioner is a "qualified individual," within the meaning of section...

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