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PHARES v. COMMISSIONER

Docket No. 3269-76.

36 T.C.M. 262 (1944)

T.C. Memo. 1944-59

Ronald L. and Jeanine M. Phares v. Commissioner.

United States Tax Court.

Filed March 10, 1977.

Attorney(s) appearing for the Case

Marvin J. Garbis, 1001 Keyser Bldg., Baltimore, Md., and Kenneth A. Reich, for the petitioners. Thomas C. Morrison, for the respondent.

Memorandum Opinion

IRWIN, Judge:

Respondent determined deficiencies in petitioners' income tax for the calendar years 1971 and 1972 as follows:

                                 Addition to Tax
  Year              Deficiency    Sec. 6653(b)1

  1971 ............. $ 3,873        $2,555
  1972 .............  16,701         8,351

This case was submitted for decision without trial pursuant to Rule 122(a...

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