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SULLIVAN v. COMMISSIONER

Docket No. 26618-88.

65 T.C.M. 2361 (1993)

T.C. Memo. 1993-153

David A. Sullivan v. Commissioner.

United States Tax Court.

Filed April 7, 1993.

Attorney(s) appearing for the Case

Patrick J. Murphy, 300 E. 42nd St., New York, N.Y., for the petitioner. Drita Tonuzi, for the respondent.

Supplemental Memorandum Findings of Fact and Opinion

GERBER, Judge.

In T.C. Memo. 1991-492, petitioner was held to be liable for the addition to tax for an underpayment due to negligence, under section 6653(a),1 and not entitled to an overpayment of his 1983 taxes. The U.S. Court of Appeals for the Second Circuit, in a mandate and opinion filed February 11, 1993, remanded for further proceedings...

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