PIZZARELLI v. COMMISSIONER

Docket Nos. 8407-75, 12056-78.

40 T.C.M. 156 (1980)

T.C. Memo. 1980-118

Anthony G. Pizzarelli and Helen Pizzarelli v. Commissioner.

United States Tax Court.

Filed April 14, 1980.


Attorney(s) appearing for the Case

Raymond M. Pezzo, for the petitioners. Scott D. Anderson, for the respondent.


Memorandum Findings of Fact and Opinion

STERRETT, Judge:

The statutory notice of deficiency with respect to calendar years 1969 and 1971 was dated June 16, 1975. The statutory notice concerning calendar year 1970 was dated August 8, 1978. In these statutory notices of deficiency, respondent asserted the following:

                                Sec. 6653(b)
  Year          Deficiency     Addition to Tax

  1969 ........ $12,208.45       ...

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