WORTHINGTON v. COMMISSIONER

Memorandum Opinion

GOLDBERG, Special Trial Judge:

This case is before the Court on respondent's Motion To Dismiss For Failure To State A Claim For Relief And For Damages Under I.R.C. § 6673,1 filed on February 21, 1989.

In a notice of deficiency dated October 7, 1988, respondent determined the following deficiency in and additions to petitioner's 1985 Federal income tax:*

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