RATANA v. COMMISSIONER

Docket Nos. 9581-76, 1560-77, 1135-77.

40 T.C.M. 1119 (1980)

T.C. Memo. 1980-353

Suwan Nguantri Ratana v. Commissioner. Rebecca C. Ratana v. Commissioner.

United States Tax Court.

Filed September 2, 1980.


Attorney(s) appearing for the Case

Suwan Nguantri Ratana, pro se in docket Nos. 9581-76 and 1560-77. Julie Noel Gilbert and Andrew D. Pike, for the petitioner in docket No. 1135-77.

Charles B. Zuravin, for the respondent.


Memorandum Findings of Fact and Opinion

STERRETT, Judge:

Under date of December 3, 1976 respondent issued a statutory notice of deficiency to petitioners asserting deficiencies in income tax and additions to tax as follows:

                                    Sec. 6653(b)
Calendar Year      Deficiency     Addition to Tax

   1974 ......... $ 91,582.30       $ 45,791.15
   1975 .........  415,034.63        207,517.32

Rebecca C...

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