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ESTATE OF ALLEN v. COMMISSIONER

Docket Nos. 6437-78, 8006-80.

44 T.C.M. 9 (1982)

T.C. Memo. 1982-303

Estate of Norma F. Allen, Deceased, and George L. Allen v. Commissioner.

United States Tax Court.

Filed June 2, 1982.

Attorney(s) appearing for the Case

Donald J. Forman and Howard A. Weinberger, 820 Hartford Bldg., Dallas, Tex., for the petitioners. William P. Lowrance and Linda L. Wong, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined deficiencies in the Federal income tax of George L. and Norma F. Allen in the amounts of $6,429.47, $4,414.10, and $1,738 for 1974, 1975, and 1976, respectively. For 1974 and 1975, respondent also determined additions to tax under section 6653(a).1 After concessions by both parties, three issues remain for decision:

1. Whether petitioners...

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