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POZSGAY v. COMMISSIONER

Docket No. 18244-94.

70 T.C.M. 301 (1995)

T.C. Memo. 1995-365

Michael S. Pozsgay v. Commissioner.

United States Tax Court.

Filed August 3, 1995.

Attorney(s) appearing for the Case

Anthony S. Gasaway and Nancy M. Galib, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge:

This matter is presently before the Court on respondent's Motion for Partial Summary Judgment that petitioner is liable for an addition to tax for fraud under section 6653(b)(1) and a penalty for fraud under section 6663(a) for the taxable years 1988 and 1989, respectively.1 As explained in more detail below, we agree with respondent that partial summary judgment is appropriate....

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