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BROWN v. COMMISSIONER

Docket No. 438-76.

37 T.C.M. 1003 (1978)

T.C. Memo. 1978-234

Fred A. Brown and Sue M. Brown v. Commissioner.

United States Tax Court.

Filed June 26, 1978.

Attorney(s) appearing for the Case

Earl G. Stokes, for the petitioners. Gordon W. Cook, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

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

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

  1972 ........  $2,951.08       $147.55
  1973 ........   2,494.21        124.71

After concessions, the issues remaining for decision are: (1) Whether...

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