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MORIARTY v. COMMISSIONER

Docket No. 26621-81.

48 T.C.M. 59 (1984)

T.C. Memo. 1984-249

James A. Moriarty and Patricia W. Moriarty v. Commissioner.

United States Tax Court.

Filed May 8, 1984.

Attorney(s) appearing for the Case

Louis J. Moriarty, for the petitioners. James C. Lanning, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined the following deficiencies and additions to tax in petitioners' Federal income taxes for their tax years 1975 and 1976:

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

December 31, 1975.. $5,526.00   $276.30
December 31, 1976..  7,905.59    395.28

After concessions, the following...

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