REICHENBACH v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

On September 30, 1996, respondent issued a notice of deficiency to petitioner based on his failure to file Federal income tax returns for 1993 and 1994 and report income from the receipt of wages, gain from the sale of property, and taxable distributions from qualified retirement plans. Respondent determined deficiencies and additions to tax as follows:

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