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BECKERT v. COMMISSIONER

Docket No. 10752-04.

90 T.C.M. 4 (2005)

T.C. Memo. 2005-162

Linda Louise Lodder-Beckert and Timothy Beckert, v. Commissioner.

United States Tax Court.

July 5, 2005.

Attorney(s) appearing for the Case

Linda Louise Lodder-Beckert and Timothy Beckert, pro sese.

Terry Serena, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioners petitioned the Court to redetermine a $2,476.35 deficiency in their 2001 Federal income tax and a related $929.84 late filing addition to tax under section 6651(a)(1).1 The deficiency stems in part from respondent's determination that petitioners are liable for a 10-percent additional tax under section 72(t)(1) on $20,000 that petitioner2

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