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PRING v. COMMISSIONER

Docket No. 11452-85.

57 T.C.M. 958 (1989)

T.C. Memo. 1989-340

Dennis J. Pring v. Commissioner.

United States Tax Court.

Filed July 17, 1989.

Attorney(s) appearing for the Case

Richard L. Carico, 601 Montgomery St., San Francisco, Calif., and John M. Bekins, for the petitioner. Mary E. Jansing and Alison W. Lehr, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In a termination assessment under section 6851(a),1 respondent determined petitioner's Federal income tax liabilities for 1977 through 1980. After the termination assessment, respondent issued a timely notice of deficiency and determined deficiencies in petitioner's Federal income tax liabilities as follows:

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