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SDI NETHERLANDS B.V. v. COMMISSIONER

Docket No. 23747-94.

107 T.C. 161 (1996)

SDI NETHERLANDS B.V., F.K.A. SDI INTERNATIONAL B.V., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 2, 1996.

Attorney(s) appearing for the Case

Arthur D. Pasternak, Douglas R. Cox, and Jeffrey A. Fiarman, for petitioner.

Karen E. Chandler and Kristine A. Roth, for respondent.

OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in Federal withholding taxes and additions to tax as follows:

                                Additions to tax
    Year      Deficiency        sec. 6651(a)(1)1

    1987       $678,449            $169,612
    1988        881,067             220,267
    1989        825,513             206,378
    1990        641,837...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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