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DIGGS v. COMMISSIONER

Docket No. 4818-76.

76 T.C. 888 (1981)

CHARLES C. DIGGS, JR., AND JANET H. DIGGS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 4, 1981.

Attorney(s) appearing for the Case

Hallison H. Young, for the petitioners.

Chauncey W. Tuttle, Jr., and Christina M. Burkholder, for the respondent.

NIMS, Judge:

Respondent determined the following deficiencies and additions to tax:

                                        Additions to tax
    Year                 Deficiency    under sec. 6651(a)1
    1971 ---------------- $3,448.16         $862.04
    1972 ----------------  5,767.12        1,304.78

Concessions having been made, the substantive issues remaining for decision...

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