Docket No. 33163-88.

63 T.C.M. 2063 (1992)

T.C. Memo. 1992-91

Warwick Housden v. Commissioner.

United States Tax Court.

Filed February 13, 1992.

Attorney(s) appearing for the Case

Michael C. Solner, for the petitioner. Michael E. Fernandez-Melone, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

                                                               Additions to Tax
                                             Sec.      Sec.          Sec.            Sec.       Sec.
Year                          Deficiency   6651(a)   6653(a)<...

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