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T.C. Memo. 1997-6
UNITED STATES TAX COURT
KENNETH SIEBERT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17154-94. Filed January 2, 1997.
Kenneth Siebert, pro se.
Ann S. O'Blenes and John R. Hunter, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notices dated June 28, 1994, respondent
determined deficiencies in and additions to petitioner's Federal
income taxes as follows:
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