T.C. Memo. 1997-509
UNITED STATES TAX COURT
EDWARD J. FRAMI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8333-96. Filed November 12, 1997.
Edward J. Frami, pro se.
James E. Schacht, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined income tax
deficiencies in the amounts of $11,619 and $12,195 for
petitioner's 1993 and 1994 taxable years, respectively.
Respondent also determined that petitioner's 1993 and 1994 income
tax returns were delinquent and that petitioner was liable for
additions to tax in the respective amounts of $3,391 and $3,676
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