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REGAN v. COMMISSIONER

Docket No. 1791-83.

51 T.C.M. 699 (1986)

T.C. Memo. 1986-120

S. Kevin Regan and Linda G. Regan v. Commissioner.

United States Tax Court.

Filed March 25, 1986.

Attorney(s) appearing for the Case

Louis J. Vallone, for petitioners. Thomas C. Boscarino, for respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined deficiencies in income tax for the years 1980 and 1981 in the amounts of $2,307.00 and $2,776.00, respectively, and additions to tax under section 6653(b)1 of the Internal Revenue Code in the amounts of $1,153.50 and $1,388.00 for those years, respectively.

The only issue is whether petitioners are liable for the addition to tax under section...

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