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JOHN J. WELLS, INC. v. COMMISSIONER

Docket Nos. 4690-80, 4691-80.

47 T.C.M. 1114 (1984)

T.C. Memo. 1984-79

John J. Wells, Inc. v. Commissioner. John J. Wells and Carmen Wells v. Commissioner.

United States Tax Court.

Filed February 16, 1984.

Attorney(s) appearing for the Case

Richard L. Carico, 601 Montgomery St., San Francisco, Calif., for the petitioners. William E. Bonano and Charlotte Mitchell, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

By notice of deficiency dated December 31, 1979, respondent determined the following deficiencies in the individual petitioners', John J. Wells and Carmen Wells, Federal income taxes:

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

  1972 .......... $19,295.96      $ 9,647.98
  1973 ........

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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