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SMITH v. COMMISSIONER

Docket No. 22512-84.

52 T.C.M. 691 (1986)

T.C. Memo. 1986-487

Courtney F. Smith and Imogene S. Smith v. Commissioner.

United States Tax Court.

Filed September 29, 1986.

Attorney(s) appearing for the Case

Taylor W. O'Hearn, 1700 Buckner Square, Shreveport, La., for the petitioners. George E. Gasper, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In a statutory notice of deficiency dated April 5, 1984, respondent determined the following deficiencies in and additions to petitioners' 1980 and 1981 Federal income tax liabilities:

                                    Addition to Tax
                                        I.R.C.
   Year              Deficiencies   Sec. 6653(a)(1)1...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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