Docket No. 27098-93.

72 T.C.M. 200 (1996)

T.C. Memo. 1996-338

Sheldon M. Sisson v. Commissioner.

United States Tax Court.

Filed July 24, 1996.

Attorney(s) appearing for the Case

Sheldon M. Sisson, pro se. Steven M. Roth, for the respondent.


FOLEY, Judge:

By notice of deficiency dated September 23, 1993, respondent determined additions to tax for petitioner's 1983 tax year as follows:

                  Additions to Tax
Sec. 6653(a)(1)   Sec. 6653(a)(2)     Sec. 6661(a)

  $3,351.50       50 percent of the    ...

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