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SMITH v. COMMISSIONER

Docket Nos. 20767-84, 37336-85, 37204-86.

54 T.C.M. 1535 (1988)

T.C. Memo. 1988-18

Jon P. Smith and Carol A. Smith v. Commissioner.

United States Tax Court.

Filed January 13, 1988.

Attorney(s) appearing for the Case

Victoria Sherlock and Bruce Locke, 1200 Smith St., Houston, Tex., for the petitioner Jon P. Smith. Alan Tinsley and Thomas Redding, for the petitioner Carol A. Smith. M. Kathryn Bellis and Marion S. Friedman, for the respondent.

Memorandum Opinion

WILLIAMS, Judge:

The Commissioner determined deficiencies and additions to tax in petitioners' 1978, 1979 and 1980 Federal income tax as follows:


                                                     Additions to tax
Year                         Deficiency   Section 6653(a)1   Section 6621(d)2
                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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