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SMITH v. COMMISSIONER

Docket No. 26787-82.

84 T.C. 889 (1985)

GEORGE F. SMITH, JR., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 20, 1985.

Attorney(s) appearing for the Case

James R. Murphy and John C. Smuck, for the petitioner.

Kristine A. Roth and Marlene Gross, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined the following deficiencies in and additions to petitioner's Federal income taxes:

                             Addition to tax
Taxable year    Deficiency   sec. 6653(a)1

   1976         $57,573.70    $2,878.69
   1977          95.897.50     4,794.88
   1978         373,930.89    18,696.54

The issues for decision are...

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