T.C. Memo. 1995-542
UNITED STATES TAX COURT
GREGORY ALBERICO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21293-93. Filed November 16, 1995.
James W. Faber, for petitioner.
William R. Davis, Jr., for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FAY, Judge: By notice of deficiency dated June 30, 1993,
respondent determined deficiencies in petitioner's income tax for
the taxable years 1990 and 1991, in the amounts of $21,478 and
$8,926, respectively, and accuracy-related penalties for the
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