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CHAMPAGNE v. COMMISSIONER

Docket No. 8454-75.

36 T.C.M. 1652 (1977)

T.C. Memo. 1977-408

Patrick Champagne and Micheline Champagne v. Commissioner.

United States Tax Court.

Filed November 28, 1977.

Attorney(s) appearing for the Case

Robert T. Doyle, for the petitioners. Thomas P. Dougherty, for the respondent.

Memorandum Findings of Fact And Opinion

HALL, Judge:

Respondent determined a deficiency in petitioners' income tax for 1971 of $2,911.79, plus an addition to the tax under section 6653(a)1 of $145.59. Because of concessions by petitioners, the issues for decision are:

(1) Whether petitioners understated their gross income in 1971 by $8,728.24.

(2) Whether any part of petitioners' underpayment of tax was due to...

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