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SUTHERLAND v. COMMISSIONER

Docket Nos. 5780-92, 21777-93, 592-94.

71 T.C.M. 1665 (1996)

T.C. Memo. 1996-1

Walton A. Sutherland v. Commissioner.

United States Tax Court.

Filed January 2, 1996.

Attorney(s) appearing for the Case

Kenneth S. Sussmane, New York, N.Y., for the petitioner. Albert G. Kobylarz and Guy G. LaVignera, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN Judge:

These three cases have been consolidated for trial, briefing and opinion. Respondent, by three notices of deficiency, determined deficiencies in, and additions to, petitioner's Federal income tax, as well as a penalty, as follows:

                                                Additions to Tax and Penalties
                                              --------------------------...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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