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BAIZER v. COMMISSIONER

Docket No. 21046-94.

75 T.C.M. 1671 (1998)

T.C. Memo. 1998-36

Neil M. Baizer v. Commissioner.

United States Tax Court.

Filed January 27, 1998.

Attorney(s) appearing for the Case

Frederick A. Romero, for the petitioner. Clifton B. Cates III, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WRIGHT, Judge:

Respondent determined deficiencies in petitioner's excise taxes imposed on prohibited transactions by section 49751 and additions to tax2 as follows:

                       First-Tier    Second-Tier                                 Additions to Tax
                       Deficiency     Deficiency...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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