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WHITMAN v. COMMISSIONER

Docket No. 1024-83.

50 T.C.M. 1322 (1985)

T.C. Memo. 1985-537

Edward and Lillian Whitman v. Commissioner.

United States Tax Court.

Filed October 21, 1985.

Attorney(s) appearing for the Case

Kenneth N. ReKant and Sidney Wertheimer (specially recognized), for the petitioners. Claudine Ryce, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

By statutory notice of deficiency dated October 26, 1982, respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:

                              Additions to Tax
  Year          Deficiency   Section 6653(a)1

  1978 .......   $ 75,843        $ 3,792
  1979 .......    236,312         11,816

The issues...

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