NADJMEHCHI v. COMMISSIONER

Docket No. 45254-86.

67 T.C.M. 2097 (1994)

T.C. Memo. 1994-42

Sattar Nadjmehchi v. Commissioner.

United States Tax Court.

Filed February 2, 1994.


Attorney(s) appearing for the Case

Victor Sherman and Janet Sherman, 2115 Main St., Santa Monica, Calif., for the petitioner. Steven M. Roth and David A. Winsten, for the respondent.


Memorandum Findings of Fact and Opinion

SWIFT, Judge:

On July 3, 1986, respondent made a jeopardy assessment against petitioner for 1985. On August 29, 1986, respondent mailed a notice of deficiency to petitioner for 1985 reflecting a deficiency in petitioner's Federal income tax and additions to tax as follows:

                                     Additions to Tax
             --------------------------------------------------------...

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