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  5. 119 T.C. 27 (2002)
 

JOHNSTON v. COMMISSIONER

Docket Nos. 26005-96, 2266-97, 12736-97.

119 T.C. 27 (2002)

119 T.C. No. 3

THOMAS E. JOHNSTON AND THOMAS E. JOHNSTON, SUCCESSOR IN INTEREST TO SHIRLEY L. JOHNSTON, DECEASED, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 8, 2002.

Attorney(s) appearing for the Case

Lorraine G. Howell, for petitioners.

Louis B. Jack, for respondent.

OPINION

NIMS, Judge:

Respondent determined the following deficiencies and penalties with respect to petitioners' Federal income taxes:

                                                     Penalties

                                                  Sec.       Sec.
      Petitioner           Year   Deficiency    6662(a)      6663

  Thomas E. Johnston
   and * * * Shirley L....

                    
                    

                        

                            

                                

                                    
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