WOOLLEY v. COMMISSIONER

Docket Nos. 23923-88, 23924-88.

61 T.C.M. 2225 (1991)

T.C. Memo. 1991-131

Donna P. Woolley v. Commissioner.

United States Tax Court.

Filed March 25, 1991.


Attorney(s) appearing for the Case

Charles P. Duffy, Philip N. Jones, Steven A. Nicholes, and David A. Kekel, 1100 S.W. 6th Ave., Portland, Ore., for the petitioner. Karen E. Stratton, for the respondent.


Memorandum Findings of Fact and Opinion

GERBER, Judge:

By means of two notices of deficiency, respondent determined deficiencies in Federal income tax and additions to tax for petitioner's 1981 through 1984 taxable years, as follows:

                                  Additions to Tax
                              -----------------------
                                  Sec.
Year              Deficiency   6653...

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