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SCHEIBNER v. COMMISSIONER

Docket No. 38939-84.

52 T.C.M. 586 (1986)

T.C. Memo. 1986-459

Ralph B. Scheibner and Donna R. Scheibner v. Commissioner

United States Tax Court.

Filed September 18, 1986.

Attorney(s) appearing for the Case

Ralph B. Scheibner and Donna R. Scheibner, pro se. Kenneth A. Hochman and David R. Smith, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In a statutory notice of deficiency dated August 14, 1984, respondent determined a deficiency in petitioners' Federal income tax liability for 1981 in the amount of $11,340. Respondent also determined that petitioners are liable for additions to tax for negligence under section 6653(a)(1)1 in the amount of $567 and under section 6653(a)(2) in an

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