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WEBB v. COMMISSIONER

Docket Nos. 9470-86, 25468-86.

55 T.C.M. 245 (1988)

T.C. Memo. 1988-80

Gene and Debra Webb v. Commissioner.

United States Tax Court.

Filed February 29, 1988.

Attorney(s) appearing for the Case

J. Richard Staley, for the petitioners. Michael Jorgenson, for the respondent.

Memorandum Findings of Fact and Opinion

PAJAK, Special Trial Judge:

In these consolidated cases, respondent determined deficiencies in, and additions to, petitioners' Federal income tax as follows:

                                                      Additions To Tax Under Sections
  Year                          Deficiencies    6651(a)(1)    6651(a)(1)    6653(a)(2)1
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