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SMITH v. COMMISSIONER

Docket No. 6556-71.

35 T.C.M. 512 (1976)

T.C. Memo. 1976-114

Charles Smith and Irene Smith v. Commissioner.

United States Tax Court.

Filed April 12, 1976.

Attorney(s) appearing for the Case

Murray M. Weinstein and Samuel J. Weinstein, 217 Broadway, New York, N.Y., for the petitioners. John J. O'Toole, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Chief Judge:*

Respondent determined the following deficiencies in petitioners' Federal income taxes and additions thereto:

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

  1959 ...... $ 8,192.71     $4,096.36
  1960 ......     527.39        263.70
  1961 ......  10,178.12      5,089.06

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