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SONG v. COMMISSIONER

Docket No. 17162-90.

63 T.C.M. 3091 (1992)

T.C. Memo. 1992-315

Si K. and Cho J. Song v. Commissioner.

United States Tax Court.

Filed June 4, 1992.

Attorney(s) appearing for the Case

Si K. & Cho J. Song, pro se. Joseph K. Fletcher III, for the respondent.

Memorandum Opinion

FAY, Judge.

Respondent determined the following deficiency in and additions to petitioners' Federal income taxes for 1985:

                             Additions to Tax
             ----------------------------------------------
Deficiency   Sec. 6653(b)(1)1   Sec. 6653(b)(2)   Sec. 6661(a)

$949,489        $474,745             *           $237,372

* 50...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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