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SEWARD v. COMMISSIONER

Docket Nos. 17481-88, 18100-89.

62 T.C.M. 1567 (1991)

T.C. Memo. 1991-632

Charles P. Seward and Joan A. Seward v. Commissioner.

United States Tax Court.

Filed December 19, 1991.

Attorney(s) appearing for the Case

Robert C. Barrett, Jr., 5329 Dijon, Baton Rouge, La., for the petitioners. Scott T. Welch and Linda J. Bourquin, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

In deficiency notices dated April 18, 1989, and April 11, 1988, respectively, respondent determined deficiencies in and additions to petitioners' Federal income taxes for 1981 and 1984 as follows:

                                                         Additions to tax
                                              -------------------------------------------
                          ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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