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NADLER v. COMMISSIONER

Docket No. 16783-90.

64 T.C.M. 70 (1992)

T.C. Memo. 1992-383.

David Nadler v. Commissioner.

United States Tax Court.

Filed July 8, 1992.

Attorney(s) appearing for the Case

Norman R. Berkowitz and Jay D. Fischer, 1450 Broadway, New York, N.Y., for the petitioner. Paul N. Schneiderman, for the respondent.

Memorandum Findings of Fact and Opinion

BEGHE, Judge:

Respondent determined deficiencies in petitioner's Federal income tax and an addition to tax as follows:

                                   Addition to tax
Year                  Deficiency   Sec. 6651(a)(1)

1979 ..............    $18,435           --
1980 ..............      7,970        $1,195.50

After concessions, the sole issue for decision is...

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