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SMITH v. COMMISSIONER

Docket No. 29685-88.

60 T.C.M. 254 (1990)

T.C. Memo. 1990-384

James E. Smith v. Commissioner.

United States Tax Court.

Filed July 25, 1990.

Attorney(s) appearing for the Case

David B. Smith and Gregory B. English, 1101 Duke St., Alexandria, Va., for the petitioner. Lindsey D. Stellwagen, for the respondent.

Memorandum Opinion

COHEN, Judge:

Respondent determined deficiencies of $40,442.08, $36,470.15, and $152,422.06 in petitioner's Federal income taxes for 1984, 1985, and 1986, respectively. Respondent also determined additions to tax for fraud as follows:


Year      Section              Amount

1984   6653(b)(1)      $20,221.04
       6653(b)(2)      50% of the interest due
 ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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