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REYNOLDS v. COMMISSIONER

Docket No. 12112-97.

79 T.C.M. 1376 (2000)

T.C. Memo. 2000-20

Charles and Beatrice M. Reynolds v. Commissioner.

United States Tax Court.

Filed January 19, 2000.

Attorney(s) appearing for the Case

Thomas F. Howard, for the petitioners. Michael F. O'Donnell, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

DEAN, Special Trial Judge:

Respondent determined deficiencies of $4,732 and $3,092 in petitioners' Federal income taxes for taxable years 1993 and 1994 respectively. Respondent also determined accuracy-related penalties under section 66621 of $946 and $618 for 1993 and 1994 respectively.

Respondent concedes that petitioners are...

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