WAITZKIN v. COMMISSIONER

Memorandum Findings of Fact and Opinion

PAJAK, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rule 180, 181, and 182. (All section numbers refer to the Internal Revenue Code for the taxable year in issue. All Rule numbers refer to the Tax Court Rules of Practice and Procedure.)

Respondent determined a deficiency and additions to tax in petitioner's 1984 Federal income tax as follows:

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