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SMITH v. COMMISSIONER

Docket No. 15353-87.

62 T.C.M. 605 (1991)

T.C. Memo. 1991-419

Steve K. Smith and Diane W. Smith v. Commissioner.

United States Tax Court.

Filed August 26, 1991.

Attorney(s) appearing for the Case

Mitchell S. Fuerst, Jesse T. Mountjoy, and Timothy O. Shelburne, 100 St. Ann Bldg., Owensboro, Ky. for the petitioners.

Frederick W. Krieg, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

On December 5, 1990, respondent filed a Motion for Partial Summary Judgment. In the statutory notice of deficiency, respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:

                                                           Additions to Tax
                                              Section           Section...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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