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GAUTHIER v. COMMISSIONER

Docket No. 9403-72.

35 T.C.M. 746 (1976)

T.C. Memo. 1976-166

John T. Gauthier and Katherine J. Gauthier v. Commissioner.

United States Tax Court.

Filed May 26, 1976.

Attorney(s) appearing for the Case

Walter H. Sweeney and Charles A. McNelis, for the petitioners. Marlene Gross, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in petitioners' Federal income tax and addition to tax for the negligence penalty (section 6653(a) of the Code)1 as follows:

Year              Deficiency   Addition to Tax

1967 ..........  $    546.52     $    27.33
1968 ..........    46,909.57       2,345.48
1969 ..........   268,191.12      13,409.56

The...

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