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HEYMANN v. COMMISSIONER

Docket No. 2671-69.

29 T.C.M. 1053 (1970)

T.C. Memo. 1970-239

Paul Heymann and Marion R. Heymann v. Commissioner.

United States Tax Court.

Filed August 24, 1970.

Attorney(s) appearing for the Case

Samuel L. Black, for the petitioners. William T. Hayes, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined the following income tax deficiency and additions to tax against the petitioners:

                            Additions to Tax
  Year   Deficiency   Sec. 6651(a)    Sec. 6653(a)1

  1965    $2,628.95      $131.45        $131.45

The three issues presented for decision are:

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