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SMITH v. COMMISSIONER

Docket No. 36158-87, 402-88.

57 T.C.M. 826 (1989)

T.C. Memo. 1989-318

E. Newbold Smith and Margaret Dupont Smith v. Commissioner.

United States Tax Court.

Filed June 28, 1989.

Attorney(s) appearing for the Case

William A. Kelley, Jr., 1500 Market St., Philadelphia, Pa., for the petitioners. Kenneth J. Rubin and Joellyn R. Cattell, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

In his notices of deficiency, respondent determined the following income tax deficiencies and addition to tax for petitioners:

               Docket No. 36158-87

                                   Addition to tax
Year                  Deficiency   Section 66611

1982...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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