ROSA v. COMMISSIONER

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

On January 29, 1987, respondent made a jeopardy assessment against petitioner for 1985 and a termination assessment against petitioner for 1986. On March 18, 1987, and on June 9, 1987, respondent mailed notices of deficiency to petitioner for 1985 and 1986, reflecting deficiencies in petitioner's Federal income taxes and additions to tax as follows:

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