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HAVRILLA v. COMMISSIONER

Docket No. 4901-92.

64 T.C.M. 152 (1992)

T.C. Memo. 1992-393

Stephen Havrilla v. Commissioner.

United States Tax Court.

Filed July 15, 1992.

Attorney(s) appearing for the Case

Stephen Havrilla, pro se. Mark A. Weiner, for the respondent.

Memorandum Opinion

NAMEROFF, Special Trial Judge:

This case is before the Court on respondent's Motion to Dismiss For Failure to State a Claim, which includes a prayer for a penalty under section 6673.1 This case was assigned pursuant to section 7443A(b) and Rules 180, 181, and 182 by order of the Chief Judge.

In a notice of deficiency, respondent determined a deficiency in income tax and additions to tax due from petitioner...

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