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RICKEL v. COMMISSIONER

Docket No. 22936-87.

92 T.C. 510 (1989)

FRANK E. AND MILDRED E. RICKEL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 23, 1989.

Attorney(s) appearing for the Case

Dixon R. Rich, Ted Tishman, and Dixon R. Rich, Jr., for the petitioners.

Julia L. Wahl and Edward F. Peduzzi, for the respondent.

COHEN, Judge:

Respondent determined deficiencies in petitioners' Federal income tax liability and additions to tax for 1983 and 1984 as follows:

                                               Additions to tax                   
  Year     Deficiency      Sec. 6653(a)(1)1         Sec. 6653(a)(2)    Sec. 6661(a)

  1983     $26,551.56         $1,327.57...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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