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SURIEL v. COMMISSIONER

Docket No. 367-12.

141 T.C. 507 (2013)

VIDAL SURIEL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 4, 2013.

Attorney(s) appearing for the Case

Edward T. Yevoli , Paul D. Turner , and Joey M. Lampert , for petitioner.

Robert M. Ratchford and Jeffrey B. Fienberg , for respondent.

GOEKE, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

Year     Deficiency

2004                 $33,912,933
2006                   5,837,489

Respondent's determinations of tax deficiencies result from adjustments made following respondent's examination of returns of Vibo Corp., d.b.a. General Tobacco, Inc. (Vibo),1...

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