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CUTLER v. COMMISSIONER

Docket No. 2219-75.

36 T.C.M. 1290 (1977)

T.C. Memo. 1977-320

Philip L. Cutler and Sarita B. Cutler v. Commissioner.

United States Tax Court.

Filed September 19, 1977.

Attorney(s) appearing for the Case

J. Brian Foley, 8th Floor, Connell Bldg., Scranton, Pa., for the petitioners. Lowell F. Raeder, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined the following deficiencies in petitioners' income taxes:

                              Addition to Tax
  Year        Deficiency    Under Sec. 6653(a)1

  1968 ...... $1,404.50          $ 70.22
  1969 ......  1,691.41            84.57
  1970 ......  2,528.99           126.95

After concessions, the two issues are whether petitioners...

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