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FOSTER v. COMMISSIONER

Docket No. 489-94.

71 T.C.M. 1865 (1996)

T.C. Memo. 1996-26

Alex Morgan Foster v. Commissioner.

United States Tax Court.

Filed January 24, 1996.

Attorney(s) appearing for the Case

Alex Morgan Foster, pro se. Lloyd T. Silberzweig and Debra K. Moe, for the respondent.

MEMORANDUM OPINION

DEAN, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1

Respondent determined a deficiency of $7,197 in petitioner's 1989 Federal income tax and an accuracy-related penalty under section 6662(a) in the amount of $1,439.40.

After concessions,2 the issues for decision are: (1) Whether the proceeds...

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