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DIVINE v. COMMISSIONER

Docket Nos. 5339-65, 6667-66.

59 T.C. 152 (1972)

HAROLD S. DIVINE AND RITA K. DIVINE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 25, 1972.

Attorney(s) appearing for the Case

George V. Delson and Arnold Broser, for the petitioners.

Daniel J. Boyer, Robert D. Grossman, Jr., and Donald W. Geerhart, for the respondent.

OPINION

FORRESTER, Judge:

Respondent determined deficiencies in petitioners' income tax for the taxable years 1961 and 1962 in the amounts of $15,134.77 and $21,334.40, respectively, and also determined with respect to 1962 an addition to tax under section 6653(a)1 in the amount of $1,066.72. Due to a number of concessions2 the only two issues remaining for our decision are the following: ...

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