SCHMIDEL v. COMMISSIONER

Docket Nos. 1170-83, 588-84.

49 T.C.M. 351 (1984)

T.C. Memo. 1984-660

John C. Schmidel and Anne C. Schmidel v. Commissioner.

United States Tax Court.

Filed December 20, 1984.


Attorney(s) appearing for the Case

Richard L. Stradley, P.O. Box 128, Victor, Mont., for the petitioners. Wayne R. Appelman, 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.           Sec.
                      6653(a)1        6653(a)(2)
                      Additions       Additions
  Year     Deficiency  to Tax2         to Tax

  1979 ..    $4,706     $235            ......

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