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NACHMAN v. COMMISSIONER

Docket No. 623-94.

71 T.C.M. 3205 (1996)

T.C. Memo. 1996-288

Joseph Nachman v. Commissioner.

United States Tax Court.

Filed June 20, 1996.

Attorney(s) appearing for the Case

Joseph Nachman, pro se. Brian Condon, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined that, for 1988, petitioner is liable for a deficiency in Federal income tax of $63,600 and additions to tax of $10,779 for failure to timely file under section 6651(a) and $3,281 for negligence under section 6653(a)(1).

After concessions,1 the issues for decision are:

1. Whether petitioner's transfer of $350,000 to Swirl, Inc. (Swirl...

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