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FERRY v. COMMISSIONER

Docket No. 15842-82.

47 T.C.M. 1726 (1984)

T.C. Memo. 1984-229

Robert G. Ferry and Margaret H. Ferry v. Commissioner.

United States Tax Court.

Filed April 30, 1984.

Attorney(s) appearing for the Case

David R. Clark and William P. Shannahan, 7855 Ivanhoe Ave., La Jolla, Calif., for the petitioners. Marion K. Mortensen, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency in and an addition to petitioners' Federal income tax as follows:

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

  1978 ............. $7,857           $3,929

After concessions, the only issue is whether petitioners are liable for the addition to tax for fraud under...

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