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FARRELL v. COMMISSIONER

Docket Nos. 35307-83, 23084-84.

51 T.C.M. 1275 (1986)

T.C. Memo. 1986-262

Thomas M. Farrell and Jo Ann Farrell v. Commissioner.

United States Tax Court.

Filed June 26, 1986.

Attorney(s) appearing for the Case

R. Bertil Peterson and George Lynch (specially recognized), for the petitioners. Frank Laurino, for the respondent.

Memorandum Opinion

PARR, Judge:

Respondent determined deficiencies and additions to tax in petitioners' 1980 and 1981 Federal income tax liabilities as follows:

                                                          Additions to Tax, I.R.C. 1954
  Year                                Deficiency   Sec. 6653(a)1  Sec. 6653(a)(1)  Sec. 6653(a)(2)

  1980 ..................

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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