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HOWARD v. COMMISSIONER

Docket No. 824-91.

64 T.C.M. 1610 (1992)

T.C. Memo. 1992-729

Howard D. and Lacey M. Arnaiz v. Commissioner.

United States Tax Court.

Filed December 29, 1992.

Attorney(s) appearing for the Case

Steven A. Malcoun, 87 W. March Ln., Stockton, Calif., for the petitioners. Dale A. Zusi, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined additions to petitioners' income taxes for 1985 under sections 6651(a)(1)1 and 6654 of $22,441 and $343 respectively. Petitioners have conceded the addition to tax under section 6654.

The issue for decision is whether petitioners are liable for the addition to tax under section 6651(a)(1) for failure...

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