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FAZZIO v. COMMISSIONER

Docket No. 2748-89.

60 T.C.M. 1328 (1990)

T.C. Memo. 1990-608

Frank A. Fazzio v. Commissioner.

United States Tax Court.

Filed December 3, 1990.

Attorney(s) appearing for the Case

Leon M. Schurgin, 3000 Town Center, Southfield, Mich., Deborah S. Hack, and Chauncey W. Tuttle, Jr., for the petitioner. Margaret A. Satko, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined deficiencies in petitioner's 1984 Federal income tax in the amount of $1,079,267 and additions to tax under sections 6653(b)(1),1 6653(b)(2), and 6661 in the amounts of $539,634, 50 percent of the interest due on $1,079,267, and $269,817, respectively. Respondent also applied the increased interest rate set forth in section 6621(c).

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