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PARRIS v. COMMISSIONER

Docket No. 201-78.

40 T.C.M. 1230 (1980)

T.C. Memo. 1980-383

Nathan Parris and Helen Parris v. Commissioner.

United States Tax Court.

Filed September 16, 1980.

Attorney(s) appearing for the Case

Lawrence A. Hogan and Theron E. Mullinax, Jr., 220 S. Main St., Hendersonville, N.C., for the petitioners. Mathew E. Bates, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent has determined a deficiency in petitioners' 1975 income tax of $2,521.27 and an addition to the tax pursuant to section 6653(a)1 of $126.06. The issues for our decision are:

(1) whether respondent has accurately determined petitioners' income by use of the source and application of funds method;2 and

(2) whether petitioners...

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