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MOSTELLER v. COMMISSIONER

Docket No. 15361-81.

52 T.C.M. 758 (1986)

T.C. Memo. 1986-505

David F. Mosteller v. Commissioner.

United States Tax Court.

Filed October 7, 1986.

Attorney(s) appearing for the Case

Gerald T. Zerkin, for the petitioner. John C. McDougal, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined deficiencies in and additions to petitioner's Federal income tax as follows:

                               Sec. 6653(b)1
Year              Deficiency       Addition

1976 ............. $10,184         $ 5,092
1977 .............  44,128          22,064

After concessions by both parties,

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