T.C. Memo. 2002-55
UNITED STATES TAX COURT
HENRY A. JULICHER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1102-99. Filed February 27, 2002.
Alan L. Frank and Robert A. Cohen, for petitioner.
Keith L. Gorman and John Gilbert, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge: Respondent determined a deficiency in
petitioner’s 1994 Federal income tax of $95,727, an addition to
tax under section 6651(a)(1)1 of $23,932, and an accuracy-
1 Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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