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HEALEY v. COMMISSIONER

Docket Nos. 222-94, 2613-95.

71 T.C.M. 3148 (1996)

T.C. Memo. 1996-260

Patrick W. Healey and Nancy L. Marshall v. Commissioner.

United States Tax Court.

Filed June 6, 1996.

Attorney(s) appearing for the Case

Patrick W. Healey, for the petitioners. Lisa K. Hartnett, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined that petitioners are liable for a deficiency in Federal income tax, an addition to tax, and a penalty as follows:

                                                             Addition to      Accuracy-Related
                                                                  Tax              Penalty
Year                           ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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