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RACZKIEWICZ v. COMMISSIONER

Docket Nos. 15706-92, 23646-92.

66 T.C.M. 1761 (1993)

T.C. Memo. 1993-617

Ernest S. Raczkiewicz v. Commissioner.

United States Tax Court.

Filed December 23, 1993.

Attorney(s) appearing for the Case

Mary Ann Raczkiewicz (specially recognized), for the petitioner. William I. Miller, for the respondent.

Memorandum Opinion

GOLDBERG, Special Trial Judge:

These cases were consolidated for the purpose of trial, briefing, and opinion. The consolidated cases were heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1

Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:

                            Additions to Tax
                    -----...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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