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CLEVE v. COMMISSIONER

Docket No. 4522-83.

50 T.C.M. 1353 (1985)

T.C. Memo. 1985-546

Kenneth E. Van Cleve and Brunla A. Van Cleve v. Commissioner.

United States Tax Court.

Filed October 30, 1985.

Attorney(s) appearing for the Case

Peter R. Stromer, for the petitioners. Donna J. Rice, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

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

                              Additions to Tax
    Year          Deficiency    Sec. 6653(a)1

     1978 .........   $3,768        $231
     1979 .........    4,885         260
     1980 .........    5,062         282

After concessions, the issues...

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