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BENNETT v. COMMISSIONER

Docket No. 26408-86.

56 T.C.M. 796 (1988)

T.C. Memo. 1988-557

Edward B. and Jody G. Bennett v. Commissioner.

United States Tax Court.

Filed December 8, 1988.

Attorney(s) appearing for the Case

Mark E. Kellogg, 4157 Chain Bridge Rd., Fairfax, Va., for the petitioners. Maureen T. O'Brien, for the respondent.

Memorandum Opinion

SWIFT, Judge:

This matter is before the Court on respondent's motion for partial summary judgment. In a notice of deficiency dated April 9, 1986, respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:

                                                       Additions to Tax,
                                                Secs.1 ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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