FLEISCHNER v. COMMISSIONER

MEMORANDUM OPINION

NAMEROFF, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3)1 and Rules 180, 181, and 182.

In a notice of deficiency dated December 23, 1980, respondent determined deficiencies and additions to tax in petitioner's Federal income taxes for the taxable years 1970 through 1976 as follows:

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