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ELLIOTT v. COMMISSIONER

Docket No. 23599-95.

73 T.C.M. 3197 (1997)

T.C. Memo. 1997-294

Herbert C. Elliott v. Commissioner.

United States Tax Court.

Filed June 26, 1997.

Attorney(s) appearing for the Case

John H. Trader, Kansas City, Mo., for the petitioner. Dennis R. Onnen, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Herbert C. Elliott petitioned the Court to redetermine respondent's determination with respect to his 1991 and 1992 taxable years. Respondent determined the following income tax deficiencies and penalties for those years:

Year                 Deficiency   Penalty Sec. 6662(a)

1991 .............    $25,105           $5,021
1992 .............      9,917            1,983...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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