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CLARK v. COMMISSIONER

Docket No. 323-96.

73 T.C.M. 2716 (1997)

T.C. Memo. 1997-209

Todd A. Clark v. Commissioner.

United States Tax Court.

Filed May 5, 1997.

Attorney(s) appearing for the Case

Robert J. Gumser, San Diego, Calif., for the petitioner. Roberta D. Repasy, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Todd A. Clark petitioned the Court to redetermine respondent's determination with respect to his 1991 and 1993 taxable years. Respondent determined the following deficiencies in Federal income taxes and additions thereto:

                     Additions to Tax
                     -----------------
                       Sec.       Sec.
Year   Deficiency
                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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