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NELL v. COMMISSIONER

Docket No. 26184-83.

51 T.C.M. 1219 (1986)

T.C. Memo. 1986-246

Don E. Nell v. Commissioner.

United States Tax Court.

Filed June 17, 1986.

Attorney(s) appearing for the Case

Robert J. Degroot and Robert J. McKenna (specially recognized), 56 Park Place, Newark, N.J., for the petitioner. Daniel K. O'Brien and William S. Garofalo, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined deficiencies in petitioner's individual income tax for the calendar years 1968 and 1969 in the respective amounts of $66,225.39 and $4,178.86, together with additions to tax for each year under the provisions of section 6653(b)1 in the respective amounts of $33,112.69 and $2,089.43. By amendment to his answer filed at the time of trial, respondent...

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