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FISHER v. COMMISSIONER

Docket No. 28630-89.

64 T.C.M. 1670 (1992)

T.C. Memo. 1992-740

Robert D. Fisher and Orpha L. Fisher v. Commissioner.

United States Tax Court.

Filed December 30, 1992.

Attorney(s) appearing for the Case

William E. Farrior, for petitioners. Donald E. Edwards and Nancy S. Vozar, for respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined additions to tax for 1983 and 1984 under section 6661(a)1 (substantial understatement of liability) against petitioners as follows:

                                 Additions to Tax
Year                               Sec. 6661(a)

1983 .........................        $45...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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