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GARNER v. COMMISSIONER

Docket No. 22992-83.

54 T.C.M. 824 (1987)

T.C. Memo. 1987-510

Leonard H. Garner and Miriam A. Garner v. Commissioner.

United States Tax Court.

Filed September 29, 1987.

Attorney(s) appearing for the Case

William R. Klein, 2071 Main St., Sarasota Fla., for the petitioners. James W. Clark and Lynn C. Washington, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

On May 6, 1983, respondent issued a statutory notice of deficiency to petitioners1 for their taxable years 1976, 1977, and 1978, having determined deficiencies of $22,181, $89,042, and $17,709, for each year respectively. At trial respondent filed an Amendment to Answer, asserting the applicability of sections 6653(a)2 and 6621(d).

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