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McALISTER v. COMMISSIONER

Docket No. 7657-73.

35 T.C.M. 232 (1976)

T.C. Memo. 1976-51

Andrew J. McAlister, Jr. and Alberta L. McAlister v. Commissioner.

United States Tax Court.

Filed February 26, 1976.

Attorney(s) appearing for the Case

James L. Edgar, 6111 E. Skelly, Tulsa, Okla., for the petitioners. Michael J. O'Brien, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent has determined a deficiency in petitioners' Federal income tax for the taxable year 1970 in the amount of $2,323.56 plus an addition to tax under section 6653(a)1 in the amount of $116.18.

The issues for decision are:

(1) Whether, to the extent they remained unpaid, amounts advanced by petitioners...

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