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SCHNEER v. COMMISSIONER

Docket No. 31804-88.

97 T.C. 643 (1991)

STEPHEN B. SCHNEER AND NANCY K. SCHNEER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 12, 1991.

Attorney(s) appearing for the Case

Richard L. Gold, for the petitioners.

Andrew I. Ouslander, for the respondent.

GERBER, Judge:

Respondent, by means of separate notices of deficiency, determined deficiencies in Federal income tax for petitioners' 1984 and 1985 taxable years in the amounts of $49,708 and $25,252, respectively. Respondent, in both years, also determined additions to tax under section 6653(a)(1)1 and an additional 50-percent interest on $45,437 of the 1984 deficiency and on $25,252 of...

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