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HAYES v. COMMISSIONER

Docket Nos. 14717-93, 14953-93.

69 T.C.M. 2323 (1995)

T.C. Memo. 1995-151

John H. Hayes v. Commissioner. John H. and Bonnie D. Hayes v. Commissioner.

United States Tax Court.

Filed April 4, 1995.

Attorney(s) appearing for the Case

David L. Watson, 233 Peachtree St., Atlanta, Ga., for the petitioners. Elizabeth P. Flores, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

       Year           Deficiency

Docket No. 14717-93
       1984            $17,219

Docket No. 14953-93
       1985             17,026
       1986             13,379

In respect of each deficiency, respondent determined that, because of a substantial underpayment attributable...

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