HARBOUR v. COMMISSIONER

Memorandum Findings of Fact and Opinion

NAMEROFF, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b) and Rule 180 et seq.2 Respondent determined deficiencies in income tax and additions to tax for the taxable years 1983 and 1984 as follows:

                                                      Additions to Tax Sections
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