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FARLEY v. COMMISSIONER

Docket No. 2366-84.

65 T.C.M. 1807 (1993)

T.C. Memo. 1993-31

James A. Farley and Sharon L. Farley v. Commissioner.

United States Tax Court.

Filed January 27, 1993.

Attorney(s) appearing for the Case

Kevin O'Connell, 121 S.W. Morrison St., Portland, Ore., for the petitioners. Kathey I. Shaw, for the respondent.

Memorandum Opinion

GOLDBERG, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.

Respondent determined a deficiency in petitioners' Federal income tax for tax year 1979 in the amount of $7,302 and an addition to tax under section 6651(a...

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