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REINHARDT v. COMMISSIONER

Docket No. 12321-92.

66 T.C.M. 566 (1993)

T.C. Memo. 1993-397

Virgil E. and Lorraine Reinhardt v. Commissioner.

United States Tax Court.

Filed August 30, 1993.

Attorney(s) appearing for the Case

Raymond N. McCabe and Edward M. Griffith, Jr., 50 Fountain Plaza, Buffalo, N.Y., for the petitioners. Matthew I. Root, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

The primary issue in this case is whether additions to tax for either fraud or negligence apply to petitioners, who were distributors for the Buffalo News during the years at issue.

Respondent determined deficiencies in petitioners' Federal income tax of $3,487 for 1986, $5,498 for 1987, $6,677 for 1988, and $6,281 for 1989. Respondent determined additions to tax for fraud under section 6653...

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