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TODD v. COMMISSIONER

Docket No. 5022-76.

37 T.C.M. 920 (1978)

T.C. Memo. 1978-214

James R. Todd v. Commissioner.

United States Tax Court.

Filed June 8, 1978.

Attorney(s) appearing for the Case

Leslie C. Hackler, Jr., 3160 Maple Leaf, Dallas, Tex., for the petitioner. Charles R. Billings, for the respondent.

Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined the following deficiencies and additions in petitioner's Federal income tax:

                              Addition to Tax
  Year        Deficiency     Sec. 6651(a)1

  1972 ...... $ 9,473.00          $  -0-
  1973 ......  12,156.68        3,039.17

Because of concessions, the sole issue remaining for decision is whether in 1972...

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