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SHIELDS v. COMMISSIONER

Docket No. 3962-76.

37 T.C.M. 537 (1978)

T.C. Memo. 1978-120

Robert W. Shields and Grace Shields v. Commissioner.

United States Tax Court.

Filed March 27, 1978.

Attorney(s) appearing for the Case

George Constable, 4127 The Bank of California Center, Seattle, Wash., for the petitioners. Thomas N. Tomashek, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:

                             Addition to Tax
  Year          Deficiency    Sec. 6653(b)1

  1971 ......... $1,598.47      $799.23
  1972 .........  1,000.46       500.23

In an amendment to his answer filed at the time of trial the respondent...

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