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ZIGMONT v. COMMISSIONER

Docket No. 9758-04.

92 T.C.M. 383 (2006)

T.C. Memo. 2006-233

James S. Zigmont v. Commissioner.

United States Tax Court.

October 31, 2006.

Attorney(s) appearing for the Case

Philip A. Putman, for petitioner.

Frank W. Louis, for respondent.

MEMORANDUM OPINION

WHERRY, Judge.

This case is before the Court on petitioner's motion to withdraw deemed admissions pursuant to Rule 90(f) and respondent's motion for summary judgment pursuant to Rule 121(a).1 Respondent determined the following deficiencies and additions to tax with respect to petitioner's Federal income taxes for the 2000 and 2001 taxable years:

                                 Additions to...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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