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BILZERIAN v. COMMISSIONER

Docket No. 10201-95.

82 T.C.M. 295 (2001)

T.C. Memo. 2001-187

Paul A. Bilzerian v. Commissioner.

United States Tax Court.

Filed July 24, 2001.

Attorney(s) appearing for the Case

Paul A. Bilzerian, pro se. Michael A. Pesavento, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

Respondent determined additions to petitioner's1 1986 Federal income tax as follows:

           Additions to tax                
Sec. 6653(a)(1)(A)    Sec. 6653(a)(1)(B)

    $100,233        50% of the interest due
                    on $2,004,465

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