STENGEL v. COMMISSIONER

Docket Nos. 2593-91, 6557-91.

64 T.C.M. 903 (1992)

T.C. Memo. 1992-570

Juergen Stengel v. Commissioner.

United States Tax Court.

Filed September 24, 1992.


Attorney(s) appearing for the Case

Juergen Stengel, pro se. Paul B. Burns, for the respondent.


Memorandum Findings of Fact and Opinion

COHEN, Judge:

These two cases were consolidated upon joint motion of the parties. By notice of deficiency dated December 28, 1990, respondent determined the following deficiencies in, and additions to, petitioner's Federal income taxes:

                                                              Additions to Tax
Year                            Deficiency   Sec. 6653(a)(1)(A)<...

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