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BELLOFF v. COMMISSIONER

Docket No. 3128-89.

62 T.C.M. 274 (1991)

T.C. Memo. 1991-350.

Paul F. Belloff v. Commissioner.

United States Tax Court.

Filed July 30, 1991.

Attorney(s) appearing for the Case

Emil Sebetic, 29 Park Ave., Manhasset, N.Y., for the petitioner. Diane R. Mirabito, for the respondent.

Memorandum Opinion

CLAPP, Judge:

In June 1986, respondent assessed penalties against petitioner for the tax years 1982, 1983, and 1984, pursuant to section 6700,1 relating to the promotion of abusive tax shelters. In February 1987, after having paid 15 percent of those penalties, petitioner filed a summons and complaint in the United States District Court for the Eastern District of New York (District Court), pursuant to section...

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