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POLONE v. COMMISSIONER

Docket No. 12665-00.

86 T.C.M. 698 (2003)

T.C. Memo. 2003-339

Gavin Polone v. Commissioner.

United States Tax Court.

Filed December 16, 2003.

Attorney(s) appearing for the Case

Edwin L. Norris, Jonathan M. Brenner, and Ethan D. Millar, for the petitioner.

Steven M. Roth, Mark A. Weiner, and Leslie B. Van Der Wal, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined the following deficiencies in and penalties on petitioner's Federal income tax:

                                             Penalty
Year                Deficiency              Sec. 6662
-------------                   -----                    ------
1996                       $407,880               $81,567
1997                        407,880                81,567...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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