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SMATHERS v. COMMISSIONER

Docket No. 5425-98.

79 T.C.M. 1791 (2000)

T.C. Memo. 2000-113

Bobby B. Smathers and Kathleen N. Smathers v. Commissioner.

United States Tax Court.

Filed March 30, 2000.

Attorney(s) appearing for the Case

Bobby B. Smathers and Kathleen N. Smathers, pro sese. David Delduco, for the respondent.

MEMORANDUM OPINION

THORNTON, Judge:

By separate notices of deficiency dated December 18, 1997, respondent determined deficiencies in and additions to tax relating to petitioner husband's 1991, 1993, 1994, 1995, and 1996 Federal income taxes, and petitioner wife's 1993, 1994, 1995, and 1996 Federal income taxes.

After concessions,1 the only issues for decision are:

(1) Whether we have authority under section 6512...

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