ROMANO v. COMMISSIONER

Docket No. 621-85.

101 T.C. 530 (1993)

BENEDETTO ROMANO, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 13, 1993.


Attorney(s) appearing for the Case

Murray Appleman, for petitioner.

Catherine Chastanet, for respondent.


OPINION

WELLS, Judge:

The instant case is before us on respondent's motion for summary judgment1 and motion to impose damages under section 6673. Respondent determined a deficiency in petitioner's Federal income tax as follows:

                                   Additions to tax
   Year      Deficiency     Sec. 6653(a)(1)   Sec. 6653(a)(2)

   1983      $191,895.19    ...

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