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  5. 80 T.C.M. 396 (2000)
 

WHITTINGTON v. COMMISSIONER

Docket Nos. 5208-96, 11955-96.

80 T.C.M. 396 (2000)

T.C. Memo. 2000-296

Larry Whittington v. Commissioner. Ray Whittington and Glynda Whittington v. Commissioner.

United States Tax Court.

Filed September 21, 2000.

Attorney(s) appearing for the Case

Richard D. Hall, Jr., and William B. Trevorrow, for the petitioner in Docket No. 5208-96. Ray WHittington and Glynda Whittington, pro sese in Docket No. 11955-96. Ross A. Rowley and Paul G. Topolka, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

By notices dated December 22, 1995, and March 12, 1996, respectively, respondent determined the following deficiencies in and additions to petitioners' Federal income taxes:

                                   Larry Whittington, Docket No. 5208-96

                                                       Additions to tax
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