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LANEY v. COMMISSIONER

Docket No. 24510-90.

74 T.C.M. 507 (1997)

T.C. Memo. 1997-403

Melvin J. Laney and Carolyn A. Laney v. Commissioner.

United States Tax Court.

Filed September 11, 1997.

Attorney(s) appearing for the Case

Melvin J. Laney and Carolyn A. Laney, pro sese. Diane D. Helfgott, Robert Dietz, and Kristine A. Roth, for the respondent.

[74 T.C.M. 508]

MEMORANDUM FINDINGS OF FACT AND OPINION

CHABOT, Judge:

Respondent determined deficiencies in Federal individual income tax and additions to tax under sections 6651(a)1 (failure to timely file tax returns), 6653(a)(1) (negligence, etc.), and 6661 (substantial understatement of income tax liability) against petitioners as follows:

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