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GALLAGHER v. COMMISSIONER

Docket No. 6173-79.

75 T.C. 313 (1980)

JOSEPH F. GALLAGHER AND MARY J. GALLAGHER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 26, 1980.

Attorney(s) appearing for the Case

Vincent L. Alsfeld, for the petitioners.

W. Terrence Mooney, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' income tax and additions to tax as follows:

                                 Addition to tax
      Year     Deficiency      under sec. 6653(a)

      1976        $7,271             $364
      1977        12,586              629

Concessions having been made by petitioners, the primary issue presented is whether certain...

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