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PARKIN v. COMMISSIONER

Docket No. 16169-84.

51 T.C.M. 441 (1986)

T.C. Memo. 1986-59

Steven Howard Parkin and Linda Mary Fales Parkin v. Commissioner.

United States Tax Court.

Filed February 10, 1986.

Attorney(s) appearing for the Case

Gregory K. Wanless and Robert K. Strouse, for petitioners. Erin Collins, for the respondent.

Memorandum Findings of Fact and Opinion

AARONS, Special Trial Judge:

This case was assigned to Special Trial Judge Aarons pursuant to the provisions of section 7456(d)(3) and Rules 180, 181 and 1821.

Respondent determined a deficiency in petitioners' Federal income tax for 1981 in the amount of $6,973, together with an addition to tax under section 6651(a) in the amount of $997. After concessions set forth in the Stipulation...

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