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MILNER v. COMMISSIONER

Docket No. 13124-88.

65 T.C.M. 2085 (1993)

T.C. Memo. 1993-91

William Norman and Phyllis Jane Milner v. Commissioner.

United States Tax Court.

Filed March 16, 1993.

Attorney(s) appearing for the Case

William N. Milner and Phyllis J. Milner, pro se. Michael J. Cooper and William P. Boulet, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' income tax for the calendar years 1981 and 1982 in the amounts of $23,350.59 and $21,927.20, respectively, and additions to tax under section 6653(a)(1)1 in the respective amounts of $1,167.53 and $1,096.36. Respondent also determined an addition to tax under section 6653(a)(2) for each of these years in the amount of 50 percent...

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