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FREELAND v. COMMISSIONER

Docket No. 18708-82.

51 T.C.M. 253 (1986)

T.C. Memo. 1986-10

James J. Freeland and Maxine Freeland v. Commissioner.

United States Tax Court.

Filed January 9, 1986.

Attorney(s) appearing for the Case

W. Gerald Thornton and David D. Dahl, 801 Wachovia Bank Bldg., Raleigh, N.C., for the petitioners. Edwina L. Wilson, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined that deficiencies in income tax and additions to tax are due from petitioners for the years 1977 and 1978 as set forth below:

                            Additions to Tax
Year    Deficiency   Sec. 6651(a)(1)1  Sec. 6653(a)(1)

1977    $17,378.14    $6,287.47             $1,307.49
1978      3,293.62...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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