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ROCCO v. COMMISSIONER

Docket Nos. 620-69, 621-69.

57 T.C. 826 (1972)

CHARLES ROCCO AND ELIZABETH ROCCO, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT RALPH CARLETTA AND MAE CARLETTA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 20, 1972.

Attorney(s) appearing for the Case

Martin M. Lore, for the petitioners.

James A. McNabb, Jr., for the respondent.

FEATHERSTON, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for 1966 as follows:

Docket No.            Petitioners                           Deficiencies

620-69 -------  Charles Rocco and Elizabeth Rocco -----------   $4,606
621-69 -------  Ralph Carletta and Mae Carletta -------------   11,809

The issue for decision is whether respondent, pursuant to section 1375(c),

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