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William D. Elliott, for petitioner Sharon N. Freytag.
James R. Turton, for respondent.
OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Carleton D. Powell pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with
and adopts the opinion of the Special Trial Judge that is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge: This matter is before the
Court on the motion for summary judgment of petitioner Sharon N.
Freytag (Mrs. Freytag or petitioner), filed August 20, 1996. The
facts may be summarized as follows.
By notice of deficiency issued February 10, 1986, respondent
determined deficiencies in petitioners' Federal income taxes and
additions to tax as follows:
Additions to Tax
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2)
1978 $5,000 $250 -0-
1981 53,598 2,680 50% of the interest
due on $53,598
1982 36,901 1,845 50% of the interest
due on $36,901
On May 12, 1986, petitioners filed a petition for
redetermination of the deficiencies and additions to tax. At
1 Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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