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PREJEAN v. COMMISSIONER

Docket No. 27344-81.

45 T.C.M. 535 (1983)

T.C. Memo. 1983-31

Norris J. Prejean and Kathleen A. Prejean v. Commissioner.

United States Tax Court.

Filed January 17, 1983.

Attorney(s) appearing for the Case

Barry E. Waguespack, 218 Napoleon St., Baton Rouge, La., for the petitioners. Linda J. Bourquin, for the respondent.

Memorandum Opinion

COHEN, Judge:

The facts of this case, including the amount of additional tax owing by petitioners, have been fully stipulated and the case has been submitted for decision pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The sole issue for decision is whether the addition to tax under section 6653(b)1 is to be computed on the basis of the total tax liability for the year in question or whether...

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