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SENNETT v. COMMISSIONER

Docket Nos. 4861-71, 4900-71.

69 T.C. 694 (1978)

SANDRA SENNETT AND WILLIAM SENNETT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT WILLIAM SENNETT, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 13, 1978.

Attorney(s) appearing for the Case

Paul J. Sax, Dean E. Criddle, and George G. Wolf, for the petitioners.

Peter D. Bakutes, for the respondent.

HALL, Judge:

Respondent determined the following deficiencies in petitioners' income taxes:

                                                         Sec. 6653(a)
Docket No.                     Year     Deficiency     addition to tax
4900-71 ------------------     1967      $99,092           $4,955
4861-71 ------------------     1968       12,112              606

At issue is whether under Rule 121...

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