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FOLEY v. COMMISSIONER

Docket No. 2578-82.

46 T.C.M. 1533 (1983)

T.C. Memo. 1983-600

John J. Foley, Jr. v. Commissioner.

United States Tax Court.

Filed September 26, 1983.

Attorney(s) appearing for the Case

Laurence J. Pino, for the petitioner. Willie Fortenberry, and John F. Driscoll, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

This case is before the Court on respondent's motion for summary judgment filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure.

Respondent determined the following deficiencies in, and additions to, the Federal income tax of petitioner John J. Foley, Jr.:

                                  Addition to Tax
  Year          Deficiency    under Sec. 6653(b)
                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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