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MARSHALL v. COMMISSIONER

Docket No. 35827-85.

52 T.C.M. 1160 (1986)

T.C. Memo. 1986-582

E. Pierce and Elaine T. Marshall v. Commissioner.

United States Tax Court.

Filed December 10, 1986.

Attorney(s) appearing for the Case

C.M. Meadows, Jr., 2001 Bryan Tower, Dallas, Tex., and Williams R. Cousins III, for the petitioners. Emron Pratt and A. Shawn Noonan, for the respondent.

Memorandum Opinion

WILLIAMS, Judge:

The Commissioner determined deficiencies in petitioners' Federal income tax and additions to tax for negligence for the taxable years 19771 and 1980 as follows:

                                    Section 6653(a)2
  Year                Deficiency     Addition to Tax

  1977 ............  $    901.60      $    45.08
  1980...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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