Gary A. and Frances Bybee - Page 2

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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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