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JOHNSTON v. COMMISSIONER

Docket Nos. 26005-96, 2266-97.

122 T.C. 124 (2004)

122 T.C. No. 6

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

United States Tax Court.

Filed February 11, 2004.

Attorney(s) appearing for the Case

Lorraine G. Howell and Kenneth M. Barish, for petitioners.

Nicholas J. Richards and Kevin W. Coy, for respondent.

SUPPLEMENTAL OPINION

NIMS, Judge:

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

                                                            Penalties

                                                         Sec.         Sec.
       Petitioner              Year       Deficiency    ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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