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ESTATE OF SIMKINS v. COMMISSIONER

Docket No. 3216-74.

37 T.C.M. 1388 (1978)

T.C. Memo. 1978-338

Estate of Roger Simkins, Deceased, Yvonne Simkins, Administratrix, and Yvonne Simkins v. Commissioner.

United States Tax Court.

Filed August 28, 1978.

Attorney(s) appearing for the Case

Roger V. Barth, Robert J. Bird, and Paul S. Richter, for the petitioners.

Charles B. Norris, and Thomas C. Morrison, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined a deficiency of $346,897.56 in petitioners' Federal income tax for the taxable year 1970 and an addition to tax under section 6653(a)1 of $17,344.88.

The parties have presented five issues for our determination:

(1) Whether respondent's audit and the determination in the notice of deficiency were so arbitrary and capricious as to deny...

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