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KIRWAN v. COMMISSIONER

Docket No. 15696-90.

68 T.C.M. 965 (1994)

T.C. Memo. 1994-520

Martin J. Kirwan and Gloria Kirwan v. Commissioner.

United States Tax Court.

Filed October 18, 1994.

Attorney(s) appearing for the Case

Martin J. Kirwan, pro se. James W. Ruger and Patricia Anne Golembiewski, for the respondent.

Memorandum Opinion

GOLDBERG, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(4) and Rules 180, 181 and 183.1

Respondent determined a deficiency in and additions to petitioners' Federal income tax for the taxable year 1982 as follows:

                                                                  Additions to Tax
                                                         ----...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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