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JOHN M. v. COMMISSIONER

Docket Nos. 14204-05, 14205-05.

92 T.C.M. 84 (2006)

T.C. Memo. 2006-157

John M. and Thelma Smoll v. Commissioner.

United States Tax Court.

July 31, 2006.

Attorney(s) appearing for the Case

John M. and Thelma Smoll, pro sese1;

A. Gary Begun and Elizabeth Procter, for respondent.

MEMORANDUM OPINION2

LARO, Judge:

These cases were consolidated for purposes of trial, briefing, and opinion. In a notice of deficiency dated April 28, 2005, respondent determined the following deficiencies and additions to tax with respect to John M. Smoll's (petitioner's) 1999, 2002, and 2003 Federal income taxes:

                        Additions to Tax
    Year      Tax     Sec....

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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