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ALLEN v. COMMISSIONER

Docket No. 22877-84.

92 T.C. 1 (1989)

KENNETH ALLEN AND BARBARA L. ALLEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 5, 1989.

Attorney(s) appearing for the Case

Todd Russell Reinstein and William L. Feinstein, for the petitioners.

Monica S. Melgarejo, for the respondent.

GERBER, Judge:

Respondent, in a statutory notice of deficiency dated June 11, 1984, determined a deficiency in petitioners' 1981 income tax of $4,541 and an addition under section 6653(a)(1)1 for negligence of $227 plus 50 percent of the interest on the underpayment pursuant to section 6653(a)(2). The issues for consideration are generated by petitioners' contribution to the National Institute...

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