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JACOBSON v. COMMISSIONER

Docket No. 20493-97.

78 T.C.M. 930 (1999)

T.C. Memo. 1999-401

Samuel Jacobson v. Commissioner.

United States Tax Court.

Filed December 9, 1999.

Attorney(s) appearing for the Case

Wallace Musoff, New York, N.Y., and Michael J. Coyle, for the petitioner. Moira L. Sullivan, Timothy V. Mulvey, and Vincenza Taverna, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Chief Judge:

Respondent determined deficiencies, an addition to tax, and penalties as follows:

                                                             Additions to Tax Penalties,
                                                                         I.R.C.
                                                             ---------------------------
                            ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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