Frank George - Page 1
















                                 T.C. Memo. 2002-163                                  


                               UNITED STATES TAX COURT                                


                             FRANK GEORGE, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6604-01.               Filed June 27, 2002.                 


               Frank George, pro se.                                                  
               Anne W. Durning, for respondent.                                       


                                 MEMORANDUM OPINION                                   

               COHEN, Judge:  Respondent determined deficiencies of $66,470           
          and $90,777 in petitioner’s Federal income taxes for 1996 and               
          1997, respectively, and determined penalties under section 6662             
          of $13,294 and $18,155 for those years, respectively.  The issues           
          for decision are whether petitioner had unreported income for               
          services rendered as an osteopathic physician or as a homeopathic           




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