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CONNELL v. COMMISSIONER

Docket No. 13240-82.

51 T.C.M. 1657 (1986)

T.C. Memo. 1986-333

John L. Connell and Ketna S. Connell v. Commissioner.

United States Tax Court.

Filed July 31, 1986.

Attorney(s) appearing for the Case

E. Gary Work, Jr., for the petitioners. Francis C. Mucciolo, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

In a notice of deficiency dated March 16, 1982, respondent determined the following deficiencies in petitioners' Federal income taxes:

  Year                              Deficiency

  1975 ............................  $26,724
  1976 ............................    5,164

In an amendment to his answer filed with the Court on June 21, 1983, respondent claimed an...

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