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GUENTHER v. COMMISSIONER

Docket No. 967-84.

54 T.C.M. 382 (1987)

T.C. Memo. 1987-440

Kenneth W. Guenther and Marva Guenther v. Commissioner.

United States Tax Court.

Filed August 31, 1987.

Attorney(s) appearing for the Case

Gary R. DeFrang, for the petitioners. Gerald W. Douglas, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Judge:

Respondent determined deficiencies in petitioners' income tax and additions to tax in the following amounts for the following taxable years:

Taxable                Addition to Tax
 Year     Deficiency   Section 6653(b)1

 1978      $14,603        $7,301
 1979       41,479        20,740

After concessions, the issues...

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