WHITTINGTON v. COMMISSIONER

Docket No. 13057-90.

64 T.C.M. 1618 (1992)

T.C. Memo. 1992-732

William M. Whittington v. Commissioner.

United States Tax Court.

Filed December 29, 1992.


Attorney(s) appearing for the Case

Glen A. Stankee, One E. Broward Blvd., Fort Lauderdale, Fla., for the petitioner. Sergio Garcia-Pages, for the respondent.


Memorandum Opinion

HALPERN, Judge:

By notice of deficiency dated March 19, 1990, respondent determined deficiencies and additions to tax against petitioner as follows:

                                        Additions to tax
Taxable Year               Deficiency     Sec. 6653(b)

    1979 ...............   $3,746.610      $1,873,305
    1980 ...............    3,749,352       1,874,676
    1981 .................

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