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TILLEY v. COMMISSIONER

Docket No. 2594-96.

73 T.C.M. 2763 (1997)

T.C. Memo. 1997-222

Thomas E. and Iris M. Tilley v. Commissioner.

United States Tax Court.

Filed May 12, 1997.

Attorney(s) appearing for the Case

Thomas E. Tilley and Iris M. Tilley, pro sese. James R. Rich, for the respondent.

MEMORANDUM OPINION

FOLEY, Judge:

By notice of deficiency dated November 14, 1995, respondent determined deficiencies in petitioners' Federal income taxes and accuracy-related penalties as follows:

                                         Penalty
Year                      Deficiency   Sec. 6662(a)

1991 ..................    $ 7,739       $ 1,548
1992 ..................     62,976        12,595

Unless...

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