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MITCHELL v. COMMISSIONER

Docket No. 21350-87.

70 T.C.M. 509 (1995)

T.C. Memo. 1995-411

Austin Mitchell v. Commissioner.

United States Tax Court.

Filed August 23, 1995.

Attorney(s) appearing for the Case

Alan E. Staines, for the respondent.

MEMORANDUM OPINION

GOLDBERG, Judge:

This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182,1 and is before the Court on respondent's Motion for Summary Judgment.

In two notices of deficiency2 mailed on April 15, 1987, respondent determined deficiencies in and additions to petitioner's Federal income taxes in the following amounts as set forth below...

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