FIORE v. COMMISSIONER

Docket No. 8545-76.

39 T.C.M. 64 (1979)

T.C. Memo. 1979-360

Fred P. Fiore v. Commissioner.

United States Tax Court.

Filed September 10, 1979.


Attorney(s) appearing for the Case

John Rogers Carroll, 3 Penn Center Plaza, Philadelphia, Pa., for the petitioner. Robert J. Percy, for the respondent.


Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:

                            Additions to
                             Tax under
  Year         Deficiency   Sec 6653(a)1

  1969 ....... $  1,902.81   $    95.14
  1970 .......  321,663.17    16,083.16
  1971 .......  244,444.94    12,222.25
  1972 ...

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