REGAN v. COMMISSIONER

Docket No. 41207-84.

54 T.C.M. 846 (1987)

T.C. Memo. 1987-512

Patrick S. Regan. v. Commissioner.

United States Tax Court.

Filed September 30, 1987.


Attorney(s) appearing for the Case

Martin Fedder, 210 N. Charles St., Baltimore, Md., for the petitioner. Paula Hu and Mary Corrigan Gorman, for the respondent.


Memorandum Findings of Fact and Opinion

STERRETT, Chief Judge:

By notice of deficiency dated October 19, 1984, respondent determined deficiencies in and additions to petitioner's Federal income taxes as follows:

                    Addition to tax under
Year   Deficiency    Section 6651(a)(1)1

1979    $12,269                --
1980     57,637           $11,046
1981     29,454    ...

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