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CROZIER v. COMMISSIONER

Docket No. 7846-95.

72 T.C.M. 64 (1996)

T.C. Memo. 1996-312

Arthur B. Crozier v. Commissioner.

United States Tax Court.

Filed July 10, 1996.

Attorney(s) appearing for the Case

Louis A. Ramunno and Roland Barral, for the respondent.

MEMORANDUM OPINION

CHIECHI, Judge:

This case is before the Court on respondent's motion for summary judgment pursuant to Rule 121 (motion).1 Respondent determined a deficiency in petitioner's Federal income tax for 1991 in the amount of $13,784 and an addition to tax for that year under section 6651(a) in the amount of $304.2

Background

At the time petitioner filed the petition...

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