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LUCAS v. COMMISSIONER

Docket No. 20032-91.

63 T.C.M. 2693 (1992)

T.C. Memo. 1992-207

William C. Lucas v. Commissioner.

United States Tax Court.

Filed April 7, 1992.

Attorney(s) appearing for the Case

Mary E. Wynne, for the respondent.

Memorandum Opinion

BUCKLEY, Special Trial Judge:

This case was assigned pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 It is before us on respondent's motion to dismiss for failure to state a claim for relief and to impose a penalty under section 6673.

By separate notices of deficiency, respondent determined the following deficiencies in, and additions to, petitioner's Federal income taxes:

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