KARLIN v. COMMISSIONER

Memorandum Opinion

HAMBLEN, Judge:

This case is before the Court on respondent's motion to dismiss for failure to state a claim upon which relief can be granted filed pursuant to Rule 40.1

By statutory notice of deficiency dated December 18, 1989, respondent determined deficiencies in and additions to petitioner's Federal income tax as follows:

                                 Additions to Tax
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