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LEAMY v. COMMISSIONER

Docket No. 29126-83.

85 T.C. 798 (1985)

FRANK A. AND CHARLOTTE T. LEAMY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 18, 1985.

Attorney(s) appearing for the Case

Michael Wells, for the petitioners.

Miles D. Friedman, for the respondent.

DRENNEN, Judge:

Respondent determined the following deficiencies and additions to tax in petitioners' Federal income tax:

                  Addition to tax
Year  Deficiency   sec. 6651(a)1

1979    $5,127         $524
1980     5,384          330

After concessions2 by both parties, the issues for our decision are: (1) Whether petitioners Frank A...

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