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SMACZNIAK v. COMMISSIONER

Docket No. 21448-89.

61 T.C.M. 2030 (1991)

T.C. Memo. 1991-87

Stanley J. and Mary C. Smaczniak v. Commissioner.

United States Tax Court.

Filed March 4, 1991.

Attorney(s) appearing for the Case

Stanley J. Smaczniak and Mary C. Smaczniak, pro se. Douglas R. Fortney, for the respondent.

Memorandum Opinion

PANUTHOS, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443(b) and Rules 180 et seq.1

In separate notices of deficiency dated June 5, 1989, respondent determined deficiencies and additions to tax as follows:

                                                                 Addition
              ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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