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agrees with and adopts the opinion of the Chief Special Trial
Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: These related cases
are before the Court on the parties' cross-motions for summary
judgment. As explained in more detail below, we will grant
respondent's motions for summary judgment.
Background
On May 12, 1989, respondent mailed a statutory notice of
deficiency to Frederick M. Fox (petitioner) and his former
spouse, Michelle B. Fox, determining deficiencies in and
additions to their Federal income taxes for the taxable years
1982, 1983, 1984, and 1985. On that same date, respondent mailed
a separate statutory notice of deficiency to petitioner
determining a deficiency in and additions to his Federal income
tax for the taxable year 1986. Respondent's determinations are
summarized in the following table:
Year Deficiency 6653(a)(1) 6653(a)(2) 6653(b)(1) 6653(b)(1)(A) 6653(b)(2) 6653(b)(1)(B)
interest due
on $775
interest due
on $10,864
interest due
on $19,376
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