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TOAN v. COMMISSIONER

Docket No. 17168-95.

80 T.C.M. 899 (2000)

T.C. Memo. 2000-384

Robert W. and Vivian Toan v. Commissioner.

United States Tax Court.

Filed December 19, 2000.

Attorney(s) appearing for the Case

Robert W. Toan and Vivian Toan, pro sese. Paul L. Darcy, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

This case was submitted to the Court fully stipulated under Rule 122. Respondent determined that petitioners were liable for $21, $3,099, and $578 additions to their Federal income tax for 1979, 1980, and 1981, respectively, under section 6659. The additions to tax stem from respondent's determination that petitioners were not entitled to a 1982 investment tax credit that they claimed was attributable to their interest in...

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