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JULICHER v. COMMISSIONER

Docket No. 1102-99.

83 T.C.M. 1285 (2002)

T.C. Memo. 2002-55

Henry A. Julicher v. Commissioner.

United States Tax Court.

Filed February 27, 2002.

Attorney(s) appearing for the Case

Alan L. Frank and Robert A. Cohen, for the petitioner.

Keith L. Gorman and John Gilbert, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GALE, Judge:

Respondent determined a deficiency in petitioner's 1994 Federal income tax of $95,727, an addition to tax under section 6651(a)(1)1 of $23,932, and an accuracy-related penalty under section 6662(a) of $19,145. By amendment to answer, respondent asserted an increase in the deficiency. By motion at the end of trial to conform the pleadings to the evidence under Rule 41(b)(1)...

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