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MANILOFF v. COMMISSIONER

Docket Nos. 18201-89, 12151-90.

62 T.C.M. 1192 (1991)

T.C. Memo. 1991-554

Kenneth J. Maniloff v. Commissioner.

United States Tax Court.

Filed November 5, 1991.

Attorney(s) appearing for the Case

Steven M. Harris, 950 S. Miami Ave., Miami, Fla., for the petitioner. Julius Gonzalez, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

These consolidated cases were assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(4), and Rules 180, 181 and 183.1 The Court agrees with and adopts the Special Trial Judge's opinion which is set forth below.

For each year, respondent also determined additions to tax under section 6653(b)(2) in the amount of 50 percent of the interest payable...

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