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LINDSEY, JR. v. COMMISSIONER

Dkt. No. 16843-02.

87 T.C.M. 1295 (2004)

T.C. Memo. 2004-113

Paul S. Lindsey, Jr., and Kristen L. Lindsey v. Commissioner.

United States Tax Court.

May 11, 2004.

Attorney(s) appearing for the Case

Jim J. Shoemake, Dwight E. Cole, and Matthew S. McBride, for petitioners;

Michael W. Bitner, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes, an addition to tax, and a penalty as follows:

                        Addition to Tax    Penalty
Year      Deficiency    Sec. 6651(a)(1)    Sec. 6662(a)

1996        $725,255      $171,058          $145,051
1997           4,494         --                 --

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