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O'HAGAN v. COMMISSIONER

Docket No. 20242-92.

70 T.C.M. 498 (1995)

T.C. Memo. 1995-409

James H. O'Hagan v. Commissioner.

United States Tax Court.

Filed August 22, 1995.

Attorney(s) appearing for the Case

James H. O'Hagan, pro se. John C. Schmittdiel, for the respondent.

MEMORANDUM OPINION

SCOTT, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1989 in the amount of $436,057, and an addition to tax under section 6651(a)1 in the amount of $113,836.

Respondent has conceded that petitioner is not liable for the addition to tax under section 6651(a), leaving for decision whether the amounts repaid by petitioner in 1989 for clients' funds misappropriated...

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