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KORCHAK v. COMMISSIONER

Docket No. 22105-03.

90 T.C.M. 403 (2005)

T.C. Memo. 2005-244

Ernest I. Korchak v. Commissioner.

United States Tax Court.

October 18, 2005.

Attorney(s) appearing for the Case

Robert T. Connors, for petitioner.

James Brian Urie and Gerald A. Thorpe, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge.

Respondent determined additions to petitioner's Federal income tax for 1982 of $7,019.40 under section 6653(a)(1),1 of an amount equal to 50 percent of the interest due on a $140,388 underpayment under section 6653(a)(2),2 and of $34,322.10 under section 6659.3 Respondent also determined that interest on the $140,388...

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