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HANNAN v. COMMISSIONER

Docket No. 1216-69.

52 T.C. 787 (1969)

DANIEL E. HANNAN AND JEANNE HANNAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed, August 11, 1969.

Attorney(s) appearing for the Case

Walter R. Brown, for the petitioners.

Ivan L. Onnen, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent has filed a motion to dismiss the petition on the ground that the Court lacks jurisdiction. The decision turns on the application of sections 6211, 6212, 6213, and 6659.1 Specifically, the issue is whether the section 6651 additions to tax determined by respondent are "attributable to a deficiency" in petitioners' income tax for 1959 to 1965, inclusive.

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