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ELBASHA v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 25192-13.

T.C. Memo. 2022-1

MOHAMED H. ELBASHA, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 12, 2022.

Attorney(s) appearing for the Case

Ahmed Hassan , for petitioner.

Jason P. Oppenheim and Alexandra Jamel (student), for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

Respondent determined for tax year 2008 a deficiency in tax of $44,056 and a section 66621 penalty of $8,811, and for tax year 2009 a deficiency in tax of $28,541 and a section 6662 penalty of $5,708.

Respondent moved at trial in Atlanta, Georgia...

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