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IRVING v. COMMISSIONER

Docket No. 1096-05.

92 T.C.M. 126 (2006)

T.C. Memo. 2006-169

Richard D. Irving and Cynthia A. Burrough Irving, v. Commissioner.

United States Tax Court.

August 16, 2006.

Attorney(s) appearing for the Case

Richard D. Irving and Cynthia A. Burrough Irving, pro sese.

Miriam C. Dillard, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge:

Respondent determined the following deficiencies, additions to tax, and penalties with respect to petitioners' 2000 and 2001 tax years:

                           Addition to Tax
                                   Section                Penalty
  Year        Deficiency        6651(a)(1)        
                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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