T.C. Memo. 2001-278
UNITED STATES TAX COURT
DOMINGO A. LOPEZ, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17068-99. Filed October 10, 2001.
Denis M. McDevitt, for petitioners.
Rodney J. Bartlett, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: Respondent determined that
petitioner was liable for the following additions to tax for the
years 1982 and 1983:1
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the years at issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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