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COMEY v. COMMISSIONER

Docket Nos. 5201-96, 19836-96.

82 T.C.M. 766 (2001)

T.C. Memo. 2001-275

Cristeen B. Comey v. Commissioner. David L. Comey v. Commissioner.

United States Tax Court.

Filed October 10, 2001.

Attorney(s) appearing for the Case

Cristeen B. Comey and David L. Comey, pro sese. Mark J. Miller and Frederic J. Fernandez, for the respondent.

MEMORANDUM OPINION

BEGHE, Judge:

Respondent determined the following deficiencies in and additions to petitioner Cristeen B. Comey's Federal income tax for 1991 and 1992:1

                                                           Sec. 6662       Sec. 6662
                                                          Substantial      Negligence
                                           ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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