RAYMOND v. COMMISSIONER

Docket No. 2872-75.

46 T.C.M. 1556 (1983)

T.C. Memo. 1983-607

Sherwin H. Raymond and Elizabeth Raymond v. Commissioner.

United States Tax Court.

Filed September 27, 1983.


Attorney(s) appearing for the Case

John J. O'Toole and Andrew P. Fradkin, for the petitioners. Patrick E. Whelan, for the respondent.


Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined deficiences in petitioners' Federal income taxes and imposed additions to tax under section 6653(b)1 as follows:

                                   Addition to Tax
  Year                 Deficiency   Sec. 6653(b)

  1970 ...........    $ 44,730.26    $ 22,981.46
  1971 ...........      19,230.83      11,106.21
  1972 ...........   ...

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