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WOLF v. COMMISSIONER

Docket No. 4300-90.

64 T.C.M. 322 (1992)

T.C. Memo. 1992-432

Michael A. Wolf v. Commissioner.

United States Tax Court.

Filed July 29, 1992.

Attorney(s) appearing for the Case

H. Louis Sirkin, 105 W. Fourth St., Cincinnati, Ohio, and Martin S. Pinales, for the petitioner. Robin L. Herrell, for the respondent.

Memorandum Findings of Fact and Opinion

BEGHE, Judge:

Respondent determined a deficiency in petitioner's 1983 Federal income tax and additions to tax as follows:

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

$178,345         $8,917        50% of the interest   $44,586
                               due on $178,345

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