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SINGER v. COMMISSIONER

Docket No. 28590-89.

61 T.C.M. 1720 (1991)

T.C. Memo. 1991-27

Naphtale Singer v. Commissioner.

United States Tax Court.

Filed January 23, 1991.

Attorney(s) appearing for the Case

Naphtale Singer, pro se. Robert A. Walker, Jr., for the respondent.

Memorandum Opinion

HALPERN, Judge:

This case is before us on two matters relating to petitioner's 1984 income tax liability. First, petitioner challenges respondent's determination under section 6653(a)(1)1 of a $138 addition to tax for negligence. Second, petitioner challenges respondent's determination that petitioner's claim for refund is time barred by section 6512(b)(3).

Background

A trial was held in this...

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