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GRATE v. COMMISSIONER

Docket No. 2807-75.

37 T.C.M. 194 (1978)

T.C. Memo. 1978-34

Willie E. and Mable B. Grate v. Commissioner.

United States Tax Court.

Filed January 25, 1978.

Attorney(s) appearing for the Case

Robert B. Clarkson, 19 E. Calhoun, Sumter, S.C., for the petitioners. Maurice W. Gerard and Stanley H. Smith, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined deficiencies in petitioners' Federal income tax and additions to tax under section 6653(a)1 for 1972 and 1973 as follows:

                            Additions to Tax
  Year          Deficiency  under sec. 6653(a)

  1972 ......... $826.74          $41.34
  1973 ......... $982.48          $49.12

The issues for decision...

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