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HOY v. COMMISSIONER

Docket No. 1292-71.

58 T.C. 201 (1972)

RAYMOND T. K. AU HOY AND ROSE C. AU HOY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 2, 1972.

Attorney(s) appearing for the Case

Arthur S. K. Fong, for the petitioners.

Charles W. Nyquist, for the respondent.

HOYT, Judge:

The respondent determined a deficiency of $7,948.13 in the petitioners' income tax for the year 1962.

The following issues are presented for our decision:

(1) Whether certain information contained in the petitioners' 1965 Federal income tax return constituted a "notification" sufficient to satisfy the requirements of section 1033(a)(3)(C) of the 1954 Code1 and...

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