Rolf E. Polentarutti - Page 1

                                 T.C. Memo. 1998-113                                  


                               UNITED STATES TAX COURT                                


                         ROLF E. POLENTARUTTI, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 17117-95.                   Filed March 19, 1998.           


               Rolf Polentarutti, pro se.                                             
               James F. Kearney, for respondent.                                      


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COLVIN, Judge:  Respondent determined that petitioner had a            
          deficiency in income tax for 1989 of $78,123, and was liable for            
          an addition to tax of $3,906 under section 6651(a)(1) for failure           
          to file timely and an accuracy-related penalty of $15,625 under             
          section 6662(a) for negligence.                                             






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