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DOWNS v. COMMISSIONER

Docket No. 1991-99.

79 T.C.M. 1992 (2000)

T.C. Memo. 2000-155

James L. and Eva J. Downs v. Commissioner.

United States Tax Court.

Filed May 10, 2000.

Attorney(s) appearing for the Case

James L. Downs, pro se. Rodney J. Bartlett, for the respondent.

MEMORANDUM OPINION

NAMEROFF, Special Trial Judge:

Respondent issued a notice of deficiency to petitioners for the taxable years 1982 and 1983. In the notice, respondent determined that petitioners were liable for additions to tax for negligence pursuant to section 6653(a)(1)1 of $464 and $8 for 1982 and 1983, respectively, and under section 6653(a)(2) for 50 percent of the interest due on $9,286 and $162, respectively. Respondent...

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