MIRIANI v. COMMISSIONER

Docket No. 336-73.

35 T.C.M. 555 (1976)

T.C. Memo. 1976-122

Louis C. Miriani and Vera M. Miriani v. Commissioner.

United States Tax Court.

Filed April 21, 1976.


Attorney(s) appearing for the Case

Howard W. Staiman, Joel J. Morris and Brian Sullivan, 2700 Nat'l Bank Bldg., Detroit, Mich., for the petitioners. James C. Lynch and Robert D. Kaiser, for the respondent.


Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in petitioners' Federal income tax and additions to tax1 as follows:

                               Additions to Tax
  Year          Deficiency   Section 6653(b)2

  1957 .......  $11,784.65       $ 5,892.33
  1958 .......   16,262.45         8,131.23
  1959 .......   59,870.09        29...

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