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KERRIGAN v. COMMISSIONER

Docket No. 11309-92.

70 T.C.M. 940 (1995)

T.C. Memo. 1995-483

John Edward Kerrigan and Joan Marie Kerrigan, Deceased v. Commissioner.

United States Tax Court.

Filed October 4, 1995.

Attorney(s) appearing for the Case

Jonathan David Robbins and Thomas M. McCartin, for the petitioners. Michal Cline and Warren P. Simonsen, for the respondent.

MEMORANDUM OPINION

RUWE, Judge:

Respondent determined a deficiency1 in petitioners' Federal income tax and additions to tax as follows:

                                  Additions to Tax
                                 ------------------
                                    Sec.       Sec.
Year                Deficiency   6651(a)(1)    6661

1985 ............ ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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