BARTH v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

In a statutory notice sent March 7, 1991, to Leslie R. Barth (petitioner) and Terry E. Barth (Ms. Barth), respondent determined deficiencies and additions to tax as follows:

                                      Additions to Tax
Year                     Deficiency     Sec. 6653(b)

1976 .................    $136,503        $68,252
1978 .................    ...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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