HARRISON v. COMMISSIONER

Docket No. 29324-91.

68 T.C.M. 1438 (1994)

T.C. Memo. 1994-614

Benjamin J. Harrison v. Commissioner.

United States Tax Court.

Filed December 15, 1994.


Attorney(s) appearing for the Case

Audrey J. Orlando, 2298 Sunrise Dr., San Jose, Calif., for the petitioner. Emily J. Kingston, for the respondent.*


Supplemental Memorandum Opinion

PARR, Judge:

The opinion in this case, T.C. Memo. 1994-268, was filed on June 13, 1994. In that opinion we held that (1) petitioner was not liable for additions to tax under section 66511 for failure to timely file his 1982 and 1983 tax returns because respondent did not timely raise the issue; (2) petitioner was not liable for an addition to tax under section...

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