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ALLEN v. COMMISSIONER

Docket No. 17217-81.

46 T.C.M. 1612 (1983)

T.C. Memo. 1983-619

John W. van Allen and A. Theresa van Allen v. Commissioner.

United States Tax Court.

Filed September 28, 1983.

Attorney(s) appearing for the Case

John W. van Allen, pro se, Santa Cruz, Calif. Beatrice M. Pearson, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent determined deficiencies in petitioners' income tax of $6,551 and $3,534 for their 1977 and 1978 taxable years, respectively, and section 6653(a)1 additions to tax of $328 and $177 for 1977 and 1978, respectively. The issues presented for our decision are:

(1) whether activities carried on under the name...

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