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FERGEN v. COMMISSIONER

Docket Nos. 12673-81, 4522-82.

47 T.C.M. 906 (1984)

T.C. Memo. 1984-23

Robert F. Fergen and Colleen A. Fergen v. Commissioner.

United States Tax Court.

Filed January 11, 1984.

Attorney(s) appearing for the Case

Stephen W. Hagan and Mobley M. Milam, for the petitioners. H. Steven New, for the respondent.

Memorandum Findings of of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' income taxes and addition to taxes for the years and in the amounts as follows:

                               Additions to Tax,
                                 I.R.C. 19541
Taxable      Deficiencies in    Sec.       Sec.
 Year         Income Tax     6651(a)(1)   6653(a)

 1976 .....     $ 4,235      ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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