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WILKINSON v. COMMISSIONER

Docket No. 14862-93.

71 T.C.M. 1959 (1996)

T.C. Memo. 1996-39

Tolbert S. Wilkinson and Suzanne T. Wilkinson v. Commissioner.

United States Tax Court.

Filed February 1, 1996.

Attorney(s) appearing for the Case

Irwin D. Zucker, for the petitioners. Gerald L. Brantley, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KORNER, Judge:

Respondent determined deficiencies and penalties with respect to petitioners' Federal income taxes for the years and in the amounts as follows:

                                         Penalty
Year                      Deficiency   Sec. 6662(a)

1989 ..................    $36,896       $7,379
1990 ..................     31,212        6,242

All statutory...

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