WELLS v. COMMISSIONER

Docket Nos. 7832-79, 7833-79.

47 T.C.M. 796 (1983)

T.C. Memo. 1983-788

Samuel Wells v. Commissioner. Samuel Wells and Ann Wells v. Commissioner.

United States Tax Court.

Filed December 29, 1983.


Attorney(s) appearing for the Case

Marvin J. Garbis, 1001 Keyser Bldg., Baltimore, Md., and Carolyn J. McElroy, for the petitioners. Daniel J. Wiles, for the respondent.


Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent determined a deficiency of $250,760.40, and an addition to tax pursuant to section 6653(b)1 of $125,380.20 for Samuel Wells' 1971 tax year, deficiencies of $253,497.33 and $250,170.37, respectively, for the 1972 and 1973 tax years of Samuel Wells and Ann Wells, and additions to tax pursuant to section 6653(b) of $126,748.66 and $125,085.18, respectively, for...

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