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CHAN v. COMMISSIONER

Docket No. 26426-81.

48 T.C.M. 1075 (1984)

T.C. Memo. 1984-483

Fook Kheong Chan and Kwan Yu Chan v. Commissioner.

United States Tax Court.

Filed September 10, 1984.

Attorney(s) appearing for the Case

Kenneth G. Gordon, for the petitioners. Lottie W. Cohen, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:

                                     Sec. 6653(b)1
  Year             Deficiency       Addition to Tax

  1972 .........    $11,630            $ 5,815
  1973 .........     24,722             12,361

After concessions, the issues for decision are (1) whether...

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