EMMONS v. COMMISSIONER

Docket No. 32406-86.

92 T.C. 342 (1989)

GARY M. EMMONS AND MARTHA C. EMMONS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 16, 1989.


Attorney(s) appearing for the Case

William C. Waller, Jr., for the petitioners.

Susan J. Rascoe, for the respondent.


GERBER, Judge:

Respondent, in a statutory notice of deficiency dated May 8, 1986, determined deficiencies and additions to petitioners' 1981 and 1982 income taxes as follows:

                                 Additions to tax        
  Year     Deficiency     Sec. 6653(b)1       Sec. 6661

  1981      $12,418         $6,209                   ---
  1982      ...

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