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ALLEN v. COMMISSIONER

Docket No. 23547-90.

99 T.C. 475 (1992)

R. DAN ALLEN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 6, 1992.

Attorney(s) appearing for the Case

Stephen L. Kadish, Timothy J. O'Shaughnessy, and Joseph P. Alexander, for petitioners.

J. Scott Broome, for respondent.

OPINION

RAUM, Judge:

The Commissioner determined a deficiency and additions to tax with respect to petitioner's 1987 taxable year as follows:

                                        Additions to tax

                         Sec.               Sec.                    Sec.
   Deficiency          6651(a)(1)        6653(a)(1)(A)          6653...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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