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HARBOUR v. COMMISSIONER

Docket No. 22679-90.

62 T.C.M. 1083 (1991)

T.C. Memo. 1991-532

Randy G. Harbour v. Commissioner.

United States Tax Court.

Filed October 28, 1991.

Attorney(s) appearing for the Case

Joyce Rebhun, for the petitioner. Steven Roth, for the respondent.

Memorandum Findings of Fact and Opinion

NAMEROFF, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b) and Rule 180 et seq.2 Respondent determined deficiencies in income tax and additions to tax for the taxable years 1983 and 1984 as follows:

                                                      Additions to Tax Sections
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