T.C. Memo. 1999-197
UNITED STATES TAX COURT
HENRY F. K. KERSTING, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7448-96. Filed June 17, 1999.
Leonard Thomas Bradt, for petitioner.
Henry E. O'Neill, for respondent.
MEMORANDUM OPINION
LARO, Judge: Mr. Kersting petitioned the Court on April 16,
1996, to redetermine respondent's determination of deficiencies
in petitioner's Federal income tax for 1982 through 1988.
Respondent determined petitioner had unreported income in
connection with his tax shelter promotion activities. The
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