Docket No. 13255-94.

72 T.C.M. 972 (1996)

T.C. Memo. 1996-456

Don Ballantyne and Susanne C. Ballantyne v. Commissioner.

United States Tax Court.

Filed October 10, 1996.

Attorney(s) appearing for the Case

Kevin M. Bagley, San Diego, Calif., for the petitioners. Jeffrey A. Hatfield and Mary Tseng Klaasen, for the respondent.


JACOBS, Judge:

Respondent determined the following deficiencies in, and additions to, petitioners' Federal income taxes:

                                                          Additions to Tax
Year                        Deficiency   Sec....

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