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GALLADE v. COMMISSIONER

Docket Nos. 791-94, 792-94.

106 T.C. 355 (1996)

ALFRED E. GALLADE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 28, 1996.

Attorney(s) appearing for the Case

Kenneth M. Barish, James R. McDaniel, and Bruce L. Ashton, for petitioner.

Paul B. Burns, for respondent.

GERBER, Judge:

Respondent alternatively determined a $540,716 income tax deficiency and a $135,179 addition to tax under section 66611 for the 1985 tax year, or a $537,808 income tax deficiency and a $107,562 addition to tax under section 6661 for the 1986 tax year. The issues remaining for our consideration are: (1) Whether petitioner's waiver of his pension plan benefits and use of them by his wholly owned corporation resulted...

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