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ESTATE OF SELL v. COMMISSIONER

Docket No. 21566-89.

64 T.C.M. 304 (1992)

T.C. Memo. 1992-430

Estate of Ralph F. Sell, Jr. and Patricia M. Sell v. Commissioner.

United States Tax Court.

Filed July 29, 1992.

Attorney(s) appearing for the Case

Robert G. Nath, 10505 Judicial Dr., Fairfax, Va., John P. Dedon, Dexter S. Odin, and James B. Pittleman, 9302 Lee Hwy, Fairfax, Va., for the petitioners. Kristine A. Roth, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined deficiencies in petitioners' Federal income tax and additions to the tax as follows:

                                                               Additions to Tax
Year                               Deficiency   Sec. 6651   Sec. 6653(a) or (a)(1)   Sec. 6661

1979 ...........................    $ 92,220       --         ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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