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REGISTER v. COMMISSIONER

Docket Nos. 5251-90, 5252-90.

60 T.C.M. 1200 (1990)

T.C. Memo. 1990-576

Buren S. Register, Jr. v. Commissioner.

United States Tax Court.

Filed November 5, 1990.

Attorney(s) appearing for the Case

Brian F.D. Lavelle, 11 N. Market St., Asheville, N.C., and Paul W. Horrell, for the petitioner. Frank McClanahan III, for the respondent.

Memorandum Opinion

GERBER, Judge:

On December 21, 1989, respondent mailed a notice of deficiency to petitioner, which, in part, determined that petitioner was liable for an addition to tax for fraud under section 6653(b)1 for the years 1977 and 1978. Petitioner, in a petition filed March 21, 1990, alleged that respondent erred with respect to the addition to tax, and respondent, in...

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