PARTOS v. COMMISSIONER

Memorandum Opinion

GOLDBERG, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b)(3). Unless indicated otherwise, all section references are to the Internal Revenue Code as in effect for the years in issue.

Respondent determined the following deficiencies in, and additions to, petitioner's Federal income tax:

                                                                  Additions to Tax, Sections...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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