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HARDING v. COMMISSIONER

Docket No. 22145-84.

51 T.C.M. 1461 (1986)

T.C. Memo. 1986-299

Samuel R. Harding and Deborah B. Harding v. Commissioner.

United States Tax Court.

Filed July 21, 1986.

Attorney(s) appearing for the Case

William A. Diamond, Robert L. Freed and Thomas G. Haskins, for the petitioners. William Ringuette, for the respondent.

Memorandum Opinion

DRENNEN, Judge:

Respondent determined the following income tax deficiencies and additions to tax:

                 Income Tax    Additions to Tax
Year             Deficiency      Sec. 6653(b)1

1979 ........... $3,055.42         $1,527.71
1980 ...........  4,520.31          2,260.16

The issues for decision are: (1) whether petitioners are liable...

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