HARRELL v. COMMISSIONER

Memorandum Opinion

POWELL, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1

By notice of deficiency issued on December 10, 1992, respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:

                      Additions to Tax
                    --------------------
             ...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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