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VIRGIN v. COMMISSIONER

Docket No. 8871-88.

61 T.C.M. 1907 (1991)

T.C. Memo. 1991-63

Herbert W. Virgin III and Nancy Virgin v. Commissioner.

United States Tax Court.

Filed February 20, 1991.

Attorney(s) appearing for the Case

Jerome S. Richman and Edward P. Guttenmacher, 19 W. Flagler, Miami, Fla., Susan Wynne, and John S. Bohatch, counsel for the petitioners. David R. Cohen, counsel for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

Respondent determined a deficiency of $16,316 in petitioners' joint Federal income tax for 1984 and additions to tax under section 6653(a)(1) and (2).1 The issues for decision are whether respondent mailed petitioners a timely notice of deficiency and whether petitioners are liable for the additions to tax.

Findings of...

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