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DUGAN v. COMMISSIONER

Docket No. 13588-83.

49 T.C.M. 586 (1985)

T.C. Memo. 1985-38

James C. Dugan v. Commissioner.

United States Tax Court.

Filed January 22, 1985.

Attorney(s) appearing for the Case

Patrick B. Mathis, 7705 W. Main St., Belleville, Ill., and John J. Vassen, for the petitioner. Michael W. Bitner for the respondent.

Memorandum Opinion

CHABOT, Judge:

This case is before the Court on petitioner's motion to suppress, deny presumptive correctness and shift the burden of proof to respondent, treated as a motion to shift the burden of going forward with the evidence to respondent.

Respondent determined deficiencies in Federal individual income taxes and additions to tax under sections 6653(b)1 (fraud) and 6654 (underpayment of estimated...

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