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FROEHLICH v. COMMISSIONER

Docket No. 15382-94.

72 T.C.M. 1130 (1996)

T.C. Memo. 1996-487

Lee D. Froehlich v. Commissioner.

United States Tax Court.

Filed October 29, 1996.

Attorney(s) appearing for the Case

Steve Mather, for the petitioner. Mark A. Weiner, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined a deficiency in petitioner's 1987 Federal income tax in the amount of $94,794, and an addition to tax pursuant to section 66611 in the amount of $23,699. Respondent also determined a deficiency in petitioner's 1990 Federal income tax in the amount of $4,983 and an accuracy-related penalty pursuant to section 6662(a) of $997.

The principal controversy...

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