RAUCH v. COMMISSIONER

Docket No. 591-81.

47 T.C.M. 1398 (1984)

T.C. Memo. 1984-161

Douglas P. Rauch and Rosalie Rauch, Judal Construction Co., Inc., and Douglas P. Rauch (Transferee) v. Commissioner.

United States Tax Court.

Filed April 2, 1984.


Attorney(s) appearing for the Case

John J. O'Toole and Andrew Fradkin, for the petitioners. Daniel K. O'Brien and John W. Wertz, for the respondent.


Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined deficiencies in income tax and additions to tax against petitioners for the following periods and in the following amounts:

                            Addition To Tax
  Taxable Year               Under Section
     Ending     Deficiency      6653(b)1
           Douglas P. Rauch
           and Rosalie Rauch

  Dec. 31, 1966 .....

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