HENDRICKSON, Judge.
This is an accelerated calendar appeal taken by appellants, John C. Gibson, Sr. and Mary E. Gibson, from a decision and order of the Ohio Board of Tax Appeals. The facts are not in dispute.
In 1976, appellants timely filed their federal and state tax returns. Appellants having signed waivers and time extensions, their federal return was audited and adjusted in 1986, creating a deficiency. In 1987, the Ohio Tax Commissioner informed appellants...
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