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McMAHAN v. COMMISSIONER

Docket No. 13252-87.

70 T.C.M. 1354 (1995)

T.C. Memo. 1995-547

David Bruce McMahan v. Commissioner.

United States Tax Court.

Filed November 20, 1995.

Attorney(s) appearing for the Case

David J. Fischer and Matthew D. Lerner, for the petitioner. Lyle B. Press and David Williams, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

Respondent determined a deficiency of $1,555,601 in petitioner's 1982 Federal income tax and an addition to tax pursuant to section 6651(a)(1)1 in the amount of $337,264.

The issue in this case is whether petitioner, who relied on his employee to file an application for an extension of time to file his 1982 Federal income tax return, had reasonable cause for not filing...

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