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vacating and remanding in part without published opinion T.C.
Memo. 1993-232.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1982, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
All references to petitioner, singular, are to Gary A. Bybee.
In Bybee v. Commissioner, T.C. Memo. 1993-232, we sustained
respondent's Federal income tax deficiency determinations and
additions to tax for 1982, 1983, and 1984, as reflected in the
schedule below:
Additions to Tax
Year Deficiency Sec. 6653(a)(1)Sec. 6653(a)(2)Sec. 6661
1982 $11,047 $552 * $1,105
1983 13,503 675 * 1,350
1984 11,957 598 * 1,196
* 50 percent of interest due on portion of underpayment
attributable to negligence.
In Bybee v. Commissioner, supra, the Court of Appeals for
the Ninth Circuit affirmed our decision relating to petitioners'
1983 and 1984 Federal income tax deficiencies and additions to
tax. With regard, however, to our decision relating to
petitioners' 1982 Federal income tax deficiency and additions to
tax, the Court of Appeals for the Ninth Circuit questioned
whether respondent's notice of deficiency was timely mailed
pursuant to section 6501(a) and remanded that question to us for
our consideration.
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