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TOBEY v. COMMISSIONER

Docket No. 1144-70.

60 T.C. 227 (1973)

MARK TOBEY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 17, 1973.

Attorney(s) appearing for the Case

Arthur G. Barnett, William Merchant Pease, and Meade Emory, for the petitioner.

Eugene H. Flood, for the respondent.

OPINION

DAWSON, Judge:

Respondent determined the following deficiencies in petitioner's Federal income taxes:

   Taxable year                              Deficiency

   1965 -----------------------------------  $10,283.89
   1966 -----------------------------------    5,372.38

In an amended petition the petitioner has claimed overpayments for each of these years.

The issue presented for our decision...

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