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SIMPSON v. COMMISSIONER

Docket No. 23537-95.

73 T.C.M. 2764 (1997)

T.C. Memo. 1997-223

Scott C. and Patricia A. Simpson v. Commissioner.

United States Tax Court.

Filed May 12, 1997.

Attorney(s) appearing for the Case

Scott C. and Patricia A. Simpson, pro sese. Bryan E. Sladek, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

By notice dated August 17, 1995, respondent determined deficiencies in petitioners' Federal income taxes and an accuracy-related penalty as follows:

                                         Penalty
Year                      Deficiency   Sec. 6662(a)

1992 ..................    $11,255        $108
1993 ..................     16,342         --

Unless...

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