Sharon Yakira - Page 1

                                 T.C. Memo. 1998-415                                  


                               UNITED STATES TAX COURT                                


                            SHARON YAKIRA, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 27221-96.             Filed November 18, 1998.              


               Steve Mather, for petitioner.                                          
               Daniel M. Whitley, for respondent.                                     


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               VASQUEZ, Judge:  Respondent determined a deficiency of                 
          $145,517, an addition to tax under section 6651(a)(1) of $14,552,           
          and a penalty under section 6662(a) of $29,103 with respect to              
          petitioner's 1989 Federal income tax.1                                      

               1  All section references are to the Internal Revenue Code             
          in effect for the year in issue, and all Rule references are to             
                                                             (continued...)           




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