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CAFFERY v. COMMISSIONER

Docket No. 2799-88.

60 T.C.M. 807 (1990)

T.C. Memo. 1990-498

Jefferson D. Caffery v. Commissioner.

United States Tax Court.

Filed September 20, 1990.

Attorney(s) appearing for the Case

William J. Friedman, Jr., 700 St. John St., LaFayette, La., for the petitioner. Stevens E. Moore, for the respondent.

Memorandum Findings of Fact and Opinion

KORNER, Judge:

For the calendar year 1979, respondent determined a deficiency of income tax against petitioner in the amount of $469,540.50, together with additions to tax under section 6653(b)1 in the amount of $234,770.25, and under section 6654(a) in the amount of $12,947.30. After a concession by respondent, we must decide whether respondent's determinations that petitioner received...

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