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PIERSON v. COMMISSIONER

Docket No. 8030-73.

35 T.C.M. 1256 (1976)

T.C. Memo. 1976-281

Melvin Pierson and Marjorie M. Pierson v. Commissioner.

United States Tax Court.

Filed September 2, 1976.

Attorney(s) appearing for the Case

Thomas D. Roberts and Martin S. Wohl, for the petitioners. Richard H. Gannon, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in petitioners' Federal income tax for the taxable years 1964 and 1965 in the amounts of $8,110.21 and $14,140.20, respectively. In addition, the Commissioner asserted negligence penalties pursuant to the provisions of section 6653(a),1 Internal Revenue Code of 1954, in the amounts...

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