URWYLER v. COMMISSIONER

Memorandum Opinion

GALLOWAY, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1954, as amended, and Rule 180 et seq.1

In separate notices of deficiency for each taxable year dated January 19, 1989, respondent determined deficiencies in, and additions to, petitioner's Federal income taxes as follows:

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