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RICHARD E. & ELIZABETH S. NILSEN v. COMMISSIONER

Docket Nos. 17295-99, 17296-99.

82 T.C.M. 7 (2001)

T.C. Memo. 2001-163

Richard E. & Elizabeth S. Nilsen v. Commissioner.

United States Tax Court.

Filed July 3, 2001.

Attorney(s) appearing for the Case

Jerome L. Blut, for the petitioners. Timothy S. Sinnott, for the respondent.

MEMORANDUM OPINION

COUVILLION, Special Trial Judge:

In these consolidated cases, respondent determined that petitioners were liable for the following additions to tax for the years 1982 and 1983:1

                                                              Additions to Tax
                                                   Sec.
Year                                            6653(a)(1)...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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