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STIEHA v. COMMISSIONER

Docket No. 44082-86.

89 T.C. 784 (1987)

KENNETH E. STIEHA JR., AND LEE E. STIEHA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court

Filed October 8, 1987.

Attorney(s) appearing for the Case

Michael E. Kearney, for the petitioner.

Thomas E. Crowe, for the respondent.

OPINION

WILLIAMS, Judge:

This case is before us on petitioners' motion for litigation costs seeking $3,900 in attorneys' fees. In his notice of deficiency dated August 13, 1986, the Commissioner determined deficiencies in petitioners' Federal income tax for the taxable years 19791 and 1982 and an addition to tax for the taxable year 1982 as follows:

                      Sec. 6653(a)
                        

                            

                                
                            

                            

                                

                                    
    
                                        
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