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BROWN v. COMMISSIONER

Docket No. 5746-75,

36 T.C.M. 581 (1977)

T.C. Memo. 1977-138

Ellis V. Brown and Dorothy J. Brown v. Commissioner.

United States Tax Court.

Filed May 10, 1977.

Attorney(s) appearing for the Case

William R. Bagby, 1107 First National Bank Bldg., Lexington, Ky., for the petitioners. Jack A. Joynt, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

                               Sec. 6653(b)
  Year           Deficiency  addition to tax1

  1968 ........  $31,547.55    $15,773.78
  1969 ........    4,721.74      2,360.87

The issues both as to the underlying deficiencies and additions to tax depend upon...

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