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JERKINS v. COMMISSIONER

Docket No. 39562-87.

62 T.C.M. 1270 (1991)

T.C. Memo. 1991-571

T. Louis Jerkins and Diana L. Jerkins v. Commissioner.

United States Tax Court.

Filed November 25, 1991.

Attorney(s) appearing for the Case

P. Kevin Walther and Michael L. Morgan, 3169 Holcomb Bridge Rd., Norcross, Ga., for the petitioners.

T. Louis Jerkins and Diana L. Jerkins. Eric B. Jorgensen, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined a deficiency in petitioners' 1983 Federal income tax in the amount of $37,321, a $1,866 addition to tax under section 6653(a)(1)1 plus an additional amount equal to 50 percent of the interest due solely to negligence under section 6653(a)(2), and a $9,330 addition to tax under section 6661.

After concessions,2 the...

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