ROSE v. COMMISSIONER

Docket No. 1663-75.

70 T.C. 558 (1978)

ALBERT E. AND EDWINA ROSE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 24, 1978.


Attorney(s) appearing for the Case

William J. McCarvel, for the petitioners.

S. Clay Freed and Stewart C. Walz, for the respondent.


OPINION

IRWIN, Judge:

Respondent determined deficiencies in petitioners' income tax and additions to tax for the calendar years 1970 and 1971 as follows:

                                                Addition to tax
Year                    Deficiency      Sec. 6651(a)          Sec. 6653(a)
1970 ---------------    $1,679.88           $83.99              $87.93
1971 ---------------     3,510.82   ...

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