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RUVIO v. COMMISSIONER

Docket No. 30471-87.

57 T.C.M. 254 (1989)

T.C. Memo. 1989-195

Elan Ruvio v. Commissioner.

United States Tax Court.

Filed April 27, 1989.

Attorney(s) appearing for the Case

John C. McDougal, for the respondent.

Memorandum Opinion

RUWE, Judge.

On July 2, 1987, a jeopardy assessment was made against petitioner for tax years 1984, 1985, and 1986 pursuant to section 6861(a).1 In a notice of deficiency dated August 31, 1987, respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:

                                                                     Additions to Tax
                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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