T.C. Memo. 1996-386
UNITED STATES TAX COURT
STANLEY P. ZURN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 163-93. Filed August 20, 1996.
Walter Weiss, for petitioner.
Steven Roth and Mark Weiner, for respondent.
MEMORANDUM OPINION
GERBER, Judge: Respondent determined deficiencies in and
additions to, and a penalty on, petitioner’s Federal income tax
as follows:
Additions to Tax and Penalty
Sec. Sec. Sec. Sec. Sec. Sec.
6651 6653 6653 6653 6653 Sec. 6663
Year Deficiency (a)(1) (b)(1) (b)(2) (b)(1)(A) (b)(1)(B) 6661 (a)
1985 $34,812 --- $23,770 1 --- --- $8,703 ---
1986 247,288 --- --- --- $192,009 1 61,812 ---
1987 46,021 --- --- --- 42,339 1 11,505 ---
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