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DUNCAN v. COMMISSIONER

Docket No. 16266-91.

66 T.C.M. 420 (1993)

T.C. Memo. 1993-370

John R. Duncan and Joyce A. Duncan v. Commissioner.

United States Tax Court.

Filed August 19, 1993.

Attorney(s) appearing for the Case

Gary R. DeFrang, Joseph M. Wetzel, and Russell A. Sandor, 838 S.W. First Ave., Portland, Ore., for the petitioners. Shirley M. Francis, for the respondent.

Memorandum Opinion

RUWE, Judge:

Respondent determined a deficiency in petitioners' Federal income tax and additions to tax as follows:

                        Additions to Tax
                    ------------------------
Year   Deficiency   Sec.6653(a)    Sec.6661

1988    $112,682     $5,634.10    $28,170.50

The issues for decision are: (1) Whether petitioners are allowed to deduct amounts paid...

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