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CADWALLADER v. COMMISSIONER

Docket No. 32130-87.

57 T.C.M. 1030 (1989)

T.C. Memo. 1989-356

Thomas C. Cadwallader and Judy C. Douglas v. Commissioner.

United States Tax Court.

Filed July 24, 1989.

Attorney(s) appearing for the Case

Thomas C. Cadwallader, pro se. David R. Reed, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

Year                   Deficiency   Sec. 6651(a)(1)1

1982 ...............     $  315          $78.75
1983 ...............        345
1984 ...............      1,626

After concessions, the issues are (1) whether section 280A allows petitioner...

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