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SURETY INSURANCE COMPANY OF CALIFORNIA v. COMMISSIONER

Docket No. 4202-74.

39 T.C.M. 1220 (1980)

T.C. Memo. 1980-70

Surety Insurance Company of California v. Commissioner.

United States Tax Court.

Filed March 13, 1980.

Attorney(s) appearing for the Case

Frank I. Fullenwider, for the petitioner. John O. Kent, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined the following deficiencies in petitioner's Federal income taxes:

     Year                 Deficiency

     1969 ............... $13,026.15
     1970 ...............  64,258.34

By amendment to his answer the respondent increased the deficiencies for 1969 and 1970 to $32,323.63 and $112,933.67, respectively. The issues presented for our decisions are:<...

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