Frederick M. Fox - Page 2

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          agrees with and adopts the opinion of the Chief Special Trial               
          Judge, which is set forth below.                                            
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
          PANUTHOS, Chief Special Trial Judge:  These related cases                   
          are before the Court on the parties' cross-motions for summary              
          judgment.  As explained in more detail below, we will grant                 
          respondent's motions for summary judgment.                                  
          Background                                                                  
          On May 12, 1989, respondent mailed a statutory notice of                    
          deficiency to Frederick M. Fox (petitioner) and his former                  
          spouse, Michelle B. Fox, determining deficiencies in and                    
          additions to their Federal income taxes for the taxable years               
          1982, 1983, 1984, and 1985.  On that same date, respondent mailed           
          a separate statutory notice of deficiency to petitioner                     
          determining a deficiency in and additions to his Federal income             
          tax for the taxable year 1986.  Respondent's determinations are             
          summarized in the following table:                                          

                                                                                     
          Year  Deficiency  6653(a)(1)  6653(a)(2)  6653(b)(1)  6653(b)(1)(A)  6653(b)(2)   6653(b)(1)(B)

          interest due                                                                
          on $775                                                                     

          interest due                                                                
          on $10,864                                                                  

          interest due                                                                
          on $19,376                                                                  






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