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CUNNINGHAM v. COMMISSIONER

Docket Nos. 30399-85, 5536-86.

53 T.C.M. 1133 (1987)

T.C. Memo. 1987-298

Edwin J. Cunningham, Jr. and Elizabeth F. Cunningham v. Commissioner.

United States Tax Court.

Filed June 16, 1987.

Attorney(s) appearing for the Case

Paul J. Seele, 411 N. Seventh St., St. Louis, Mo., for the petitioners. Douglas W. Hinds, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:

                           Addition
                             to Tax
Year       Deficiency     Sec. 66591
1980       $10,983.59    $   --
1981         6,616.85     1,985.06
1982         7,272.67     2,158.41
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