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BROWN v. COMMISSIONER

Docket No. 17023-89.

63 T.C.M. 1750 (1992)

T.C. Memo. 1992-15

George M. Brown v. Commissioner.

United States Tax Court.

Filed January 8, 1992.

Attorney(s) appearing for the Case

Edmund J. Mendrala, 230 Park Ave., New York, N.Y., for the petitioner. William R. Davis, Jr. and Bernard Goldstein, for the respondent.

Memorandum Opinion

HALPERN, Judge:

Respondent determined for the taxable year 1982 the following deficiency and additions to tax for petitioner:

                                                              Additions to Tax
Deficiency                                     Sec. 6653(a)(1)   Sec. 6653(a)(2)   Sec. 6661

$89,423 ...................................       $4,471         50% of the         $22,356...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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