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AYER v. COMMISSIONER

Docket No. 47012-86.

58 T.C.M. 681 (1989)

T.C. Memo. 1989-614

Rita K. Ayer v. Commissioner.

United States Tax Court.

Filed November 14, 1989.

Attorney(s) appearing for the Case

Noah Nunberg and Roger E. Barton, 101 Park Ave., New York, N.Y., for the petitioner. Anne Hintermeister and William R. Davis, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined the following deficiencies in petitioner's Federal income tax and addition to tax for the following taxable years:


                                      Addition to Tax
Taxable Year            Deficiency     Sec. 6653(a)1

1972 .................  $1,378,285 ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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