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BIANCHI v. COMMISSIONER

Docket No. 8152-74.

66 T.C. 324 (1976)

ANGELO J. AND IDA A. BIANCHI, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 20, 1976.

Attorney(s) appearing for the Case

Winthrop Drake Thies, for the petitioners.

John E. White and Kenneth Bersani, for the respondent.

GOFFE, Judge:

The Commissioner determined a deficiency in petitioners' 1970 Federal income tax in the amount of $9,554.75 and addition to tax for the negligence penalty (sec. 6653(a), I.R.C. 1954) in the amount of $477.74. "Petitioner" shall hereinafter refer to petitioner Angelo J. Bianchi. The issues for decision are:

(1) Whether petitioner's wholly owned subchapter S corporation, on its initial income tax return for its first taxable year of 7

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