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CAMPBELL v. COMMISSIONER

Docket No. 6066-84.

52 T.C.M. 1096 (1986)

T.C. Memo. 1986-569

Donald R. Campbell and Patricia A. Campbell v. Commissioner.

United States Tax Court.

Filed November 26, 1986.

Attorney(s) appearing for the Case

John P. Konvalinka, 600 Tallan Bldg., Chattanooga, Tenn., and H. Wayne Grant, for the petitioners. Howard P. Levine, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1979 in the amount of $59,031.68 and additions to tax under sections 6651(a)(1)1 and 6653(a) in the respective amounts of $2,951.58 and $4,045.92. Some of the issues have been disposed of by agreement of the parties, leaving for our decision the following:

(1) Whether petitioners...

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