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EVERETT v. COMMISSIONER

Docket No. 45457-86.

56 T.C.M. 1537 (1989)

T.C. Memo. 1989-124

Michael A. Everett, Deceased, Maria Everett, Successor in Interest v. Commissioner.

United States Tax Court.

Filed March 27, 1989.

Attorney(s) appearing for the Case

Richard L. Carico, 601 Montgomery St., San Francisco, Calif., and John M. Bekins, for the petitioner and Maria Everett. Stephen R. Asmussen and Christopher J. Croudace, for the respondent.

Memorandum Opinion

PARR, Judge:

In his notice of deficiency dated August 29, 1986, respondent determined a deficiency in and additions to the calendar year 1982 Federal income tax of petitioner and his then spouse as follows:

                                                        Additions to Tax
          Deficiency          Sec. 6653(b)(1)1          Sec. 6653(b)(2)          Sec....

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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