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LINKER v. COMMISSIONER

Docket No. 2261-89.

65 T.C.M. 3019 (1993)

T.C. Memo. 1993-279

Dennis Wayne Linker v. Commissioner.

United States Tax Court.

Filed June 28, 1993.

Attorney(s) appearing for the Case

Edward P. Guttenmacher, for the petitioner. Sheldon M. Kay and Alison W. Lehr, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined a deficiency in, and an addition to, petitioner's Federal income tax for the year and in the amounts set forth below:

Year                       Deficiency   Sec. 6653(b)1

1981 ...................    $180,447     $90,223.50

Respondent determined, and petitioner does not dispute, that during the year 1981...

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