MERLINO v. COMMISSIONER

Memorandum Findings of Fact and Opinion

LARO, Judge:

This case is before the Court pursuant to the filing of a petition by Joseph Merlino (petitioner) for a redetermination of respondent's determinations set forth in a notice of deficiency issued to petitioner on October 28, 1991. The notice reflects respondent's determinations of a deficiency in, and additions to, petitioner's 1987 Federal income tax as follows:

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