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SIMPSON v. COMMISSIONER

Docket No. 16967-91.

64 T.C.M. 742 (1992)

T.C. Memo. 1992-543

Peter G. Simpson v. Commissioner.

United States Tax Court.

Filed September 15, 1992.

Attorney(s) appearing for the Case

Peter G. Simpson, pro se. Robert M. Finkel, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

This matter is before us on respondent's motion to dismiss for failure to state a claim for relief with respect to 1985, 1986, 1987, and 1988, and on respondent's motion to dismiss for lack of jurisdiction with respect to 1985, 1986, 1987, and 1989.

Respondent determined deficiencies in and additions to petitioner's Federal income taxes as follows:

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