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STONE v. COMMISSIONER

Docket No. 3812-97.

76 T.C.M. 371 (1998)

T.C. Memo. 1998-314

Jeffrey C. and Kelly O. Stone v. Commissioner.

United States Tax Court.

Filed August 31, 1998.

Attorney(s) appearing for the Case

Jeffrey C. and Kelly O. Stone, pro se. Joan S. Dennett, for the respondent.

MEMORANDUM OPINION

COLVIN, Judge:

This matter is before the Court on petitioners' motion for summary judgment. For reasons stated below, we deny petitioners' motion.

Respondent determined a deficiency in petitioners' Federal income tax for 1994 of $10,959 and an accuracy-related penalty for negligence under section 6662(a) in the amount of $2,192.

Neither party requested a hearing, and we conclude that none is necessary to decide petitioners...

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