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FINLEY v. COMMISSIONER

Docket Nos. 8967-74, 8466-76.

37 T.C.M. 1745 (1978)

T.C. Memo. 1978-421

John Finley and Dawn Finley v. Commissioner.

United States Tax Court.

Filed October 19, 1978.

Attorney(s) appearing for the Case

Thomas W. Clarke, 241 Main St., Hackensack, N.J., for the petitioners. Patrick E. Whelan, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

In these consolidated cases respondent determined deficiencies and additions to tax as follows:

                              Addition to tax
  Year           Deficiency  under sec. 6651(a)1

  1971 ........  $10,675.57    ........
  1973 ........   10,726.83   $1,403.24

The questions presented for our resolution are:

(1) Whether petitioners...

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