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STOCKS v. COMMISSIONER

Docket No. 9303-88.

98 T.C. 1 (1992)

ELEANOR L. AND JAMES A. STOCKS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 2, 1992.

Attorney(s) appearing for the Case

W. Michael Conway, for petitioners.

Roderick H. Fillinger, for respondent.

CHABOT, Judge:

Respondent determined a deficiency in Federal individual income taxes against petitioners for 1984 in the amount of $9,518,1 and additions to tax under section 6653(a)(1) (negligence, etc.) in the amount of $475.90, under section 6653(a)(2) in the amount of 50 percent of the interest on $9,518, and under section 6661(a) (substantial understatement of income tax) in the amount...

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