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ELLIOTT v. COMMISSIONER

Docket Nos. 29950-82, 28067-83.

84 T.C. 227 (1985)

JOHN M. ELLIOTT AND JANE D. ELLIOTT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 14, 1985.

Attorney(s) appearing for the Case

Marc A. Feller and Daniel F. Ryan, for the petitioners.

David Kuchinos, for the respondent.

FEATHERSTON, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

         Year                               Amount

         1978 ............................. $41,230
         1979 .............................  21,364
         1980 .............................  17,038

For 1980, respondent also determined that petitioners are liable for an addition to tax under section 6653...

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