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CLEM v. COMMISSIONER

Docket No. 16864-89.

62 T.C.M. 586 (1991)

T.C. Memo. 1991-414

William R. Clem and Janine F. Clem v. Commissioner.

United States Tax Court.

Filed August 22, 1991.

Attorney(s) appearing for the Case

Donald O'Neil Heck, for the petitioners. J. Robert Cuatto, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined the following deficiencies in and additions to petitioners' Federal income taxes:

                                     Additions to tax
Year                    Deficiency    sec. 6651(a)(1)

1979 ................    $1,220       ($286.75)
1980 ................     2,136       ( 231.75)
1981 ................     3,999         399.90
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