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SUTHERLAND v. COMMISSIONER

Docket No. 10776-88.

62 T.C.M. 1533 (1991)

T.C. Memo. 1991-619

Thomas R. Sutherland and Sally L. Sutherland v. Commissioner.

United States Tax Court.

Filed December 12, 1991.

Attorney(s) appearing for the Case

Melvin Friedman, for the petitioner Thomas R. Sutherland. Richard F. Stein, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

By statutory notice of deficiency dated March 23, 1988, respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:

                                  Additions to Tax
                                  ----------------
                                   Sec.         Sec.
Year               Deficiency   6651...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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