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KERSTING v. COMMISSIONER

Docket No. 7448-96.

77 T.C.M. 2172 (1999)

T.C. Memo. 1999-197

Henry F.K. Kersting v. Commissioner.

United States Tax Court.

Filed June 17, 1999.

Attorney(s) appearing for the Case

Leonard Thomas Bradt, for the petitioner. Henry E. O'Neill, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

Mr. Kersting petitioned the Court on April 16, 1996, to redetermine respondent's determination of deficiencies in petitioner's Federal income tax for 1982 through 1988. Respondent determined petitioner had unreported income in connection with his tax shelter promotion activities. The resulting deficiencies in income tax and additions to tax are as follows:

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