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SUMRALL v. COMMISSIONER

Docket No. 11058-97.

83 T.C.M. 1405 (2002)

T.C. Memo. 2002-78

Larry J. Sumrall and Patricia A. Sumrall v. Commissioner.

United States Tax Court.

Filed March 28, 2002.

Attorney(s) appearing for the Case

Steven A. Wilson, for the petitioners.

Mark H. Howard, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge:

By notices of deficiency dated February 24, 1997, respondent determined deficiencies in, additions to, and penalties with respect to petitioners' Federal income taxes for their taxable (calendar) years 1987 through 1991 (the audit years), as follows:

                                    Additions to Tax and Penalties
                                                 Sec.

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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