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SURIEL v. COMMISSIONER

Docket No. 367-12.

141 T.C. 507 (2013)

VIDAL SURIEL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 4, 2013.

Attorney(s) appearing for the Case

Edward T. Yevoli, Paul D. Turner, and Joey M. Lampert, for petitioner.

Robert M. Ratchford and Jeffrey B. Fienberg, for respondent.

GOEKE, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

Year     Deficiency

2004                 $33,912,933
2006                   5,837,489

Respondent's determinations of tax deficiencies result from adjustments made following respondent's examination of returns of Vibo Corp., d.b.a. General Tobacco, Inc. (Vibo),1...

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