Docket No. 16642-94.

72 T.C.M. 421 (1996)

T.C. Memo. 1996-382

Magdy S. Ellabban v. Commissioner.

United States Tax Court.

Filed August 19, 1996.

Attorney(s) appearing for the Case

Magdy S. Ellabban, pro se. Halvor N. Adams III and Joan Casali, for the respondent.


COLVIN, Judge:

Respondent determined that petitioner has a deficiency in Federal income tax of $111,795 for 1990 and additions to tax of $27,706 under section 6651(a)(1) and $797 under section 6654. Petitioner was president of Elan Leather Corp. (Elan). After concessions, we must decide the following:

1. With respect to $146,193 of Elan's income that petitioner...

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