Walter T. McGee - Page 2

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          certify this case for immediate appeal if we do not grant his               
          motion.                                                                     
               Respondent determined that petitioner had an income tax                
          deficiency of $369,390 for 1987 and was liable for additions to             
          tax for 1987 of $92,348 for failure to timely file under section            
          6651(a)(1) and $92,348 for substantial understatement of tax                
          under section 6661.                                                         
               A hearing was held on petitioner's motion in Winston-Salem,            
          North Carolina.                                                             
               We must decide the following issues:                                   
               1.   Whether respondent's deficiency determination is valid            
          for jurisdictional purposes.  We hold that it is.                           
               2.   Whether it is appropriate in this case to certify                 
          denial of petitioner's motion for interlocutory appeal.  We hold            
          that it is not.                                                             
               Section references are to the Internal Revenue Code.  Rule             
          references are to the Tax Court Rules of Practice and Procedure.            
                                     Background                                       
          A.   Petitioner                                                             
               Petitioner lived in Asheville, North Carolina, when he filed           
          the petition in this case.  In 1985, 1986, and 1987, petitioner             
          lived in Europe.  He owned several businesses that sold resort              
          time shares.  He was a director of A.T.O. Marketing Limited                 
          (A.T.O.) in 1987.  A.T.O., an Isle of Man entity, sued Kenning              
          Atlantic Iberica, NV (Kenning), a former partner.  The case was             




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