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GARRETT v. COMMISSIONER

Docket No. 9106-92.

67 T.C.M. 2214 (1994)

T.C. Memo. 1994-70

C. Anson Garrett v. Commissioner.

United States Tax Court.

Filed February 23, 1994.

Attorney(s) appearing for the Case

Richard A. Cummings, T. Steve Joyce, and Janice E. Ervin, for the petitioner. Mary P. Kimmel, for the respondent.

Memorandum Opinion

DAWSON, Judge:

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

                                     Addition to Tax
Year                    Deficiency   Sec. 6651(a)(1)

1987 ................    $117,077        $29,423
1988 ................     222,059         55,515

Some concessions have been made by respondent. The following...

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