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TALLAL v. COMMISSIONER

Docket No. 19544-84.

88 T.C. 1192 (1987)

JOSEPH J. TALLAL, JR., AND PEGGY P. TALLAL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 7, 1987.

Attorney(s) appearing for the Case

Robert K. Dowd, for the petitioners.

Val J. Albright, for the respondent.

JACOBS, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1980 in the amount of $17,897 and an addition to tax for negligence pursuant to section 6653(a)1 of $894.85. In his amended answer, respondent claimed an increased deficiency of $3,537 (for a total of $21,434), and an increased addition to tax of $327.50 (for a total addition of $1,222.35).

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