KOEHL v. COMMISSIONER

Docket No. 30851-81.

47 T.C.M. 670 (1983)

T.C. Memo. 1983-752

Charles M. and Agnes J. Koehl v. Commissioner.

United States Tax Court.

Filed December 19, 1983.


Attorney(s) appearing for the Case

Charles M. and Agnes J. Koehl, pro se. Richard F. Stein, for the respondent.


Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent mailed petitioners a statutory notice of deficiency for taxable years 1978 and 1979, on November 4, 1981, showing the following amounts of deficiencies and additions to tax:

                               Sec. 6653(a)1
    Year         Deficiency   Additions to Tax

    1978 ......... $2,849         $142.45
    1979 .........  4,428          221...

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