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KENNY v. COMMISSIONER

Docket No. 32193-88.

59 T.C.M. 468 (1990)

T.C. Memo. 1990-207

Edwin Russell Kenny, Jr. v. Commissioner.

United States Tax Court.

Filed April 23, 1990.

Attorney(s) appearing for the Case

Edwin Russell Kenny, pro se. Mark S. Mesler, for the respondent.

Memorandum Findings of Fact and Opinion

POWELL, Special Trial Judge:

For reasons that will be discussed infra, by a notice of deficiency, dated September 16, 1988, respondent determined that additions to tax under sections 6651(a)(1), 6653(a)(1) and (2) and 66611 were due from petitioner for the 1985 taxable year. Petitioner timely filed a petition contesting each of the additions to tax. At the time that the petition...

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