T.C. Memo. 1996-410
UNITED STATES TAX COURT
ROBERT J. SUGARMAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22440-94. Filed September 11, 1996.
Robert R. Elliott, for petitioner.
Linda Ann Love and Joseph M. Abele, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined deficiencies in
petitioner's Federal income tax, an addition to tax, and an
accuracy-related penalty as follows:
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1989 $9,259 $926 $877
1990 2,428 --- ---
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