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UTLEY v. COMMISSIONER

Docket No. 36975-86.

56 T.C.M. 885 (1988)

T.C. Memo. 1988-575

Walter A. Utley and Vermelle S. Utley v. Commissioner.

United States Tax Court.

Filed December 19, 1988.

Attorney(s) appearing for the Case

Arlie C. Hooper, Patti C. Bowlan, and William H. Lawson, Jr., 245 Wagner Place, Memphis, Tenn., for the petitioners. Steven R. Winningham, for the respondent.

Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

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

                                                                Additions to the Tax
      Year                    Deficiency       § 6653(a)1      § 6653(a)(1)            § 6653(a)(2)

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