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PERRY v. COMMISSIONER

Docket No. 21336-94.

74 T.C.M. 616 (1997)

T.C. Memo. 1997-417

Kenneth E. Perry and Mary A. Hofer v. Commissioner.

United States Tax Court.

Filed September 18, 1997.

Attorney(s) appearing for the Case

Bruce W. Powell, Columbus, Ohio, and Michael H. Gertner, for the petitioners. John J. Boyle, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHALEN, Judge:

Respondent determined the following deficiencies in and additions to petitioners' joint Federal income tax for the years in issue:

                                                                Additions to Tax
                                                   ------------------------------------------
                                                        Sec.        ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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