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MENGARELLI v. COMMISSIONER

Docket Nos. 6088-75, 6739-75.

47 T.C.M. 1473 (1984)

T.C. Memo. 1984-177

Albert R. Mengarelli v. Commissioner. Keith S. Richards and Estate of Judith A. Richards, Deceased v. Commissioner.

United States Tax Court.

Filed April 9, 1984.

Attorney(s) appearing for the Case

John P. Fadgen, for the petitioners. John O. Kent and Michael C. Cohen, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined the following deficiencies in, and additions to, petitioners' Federal income taxes:

_________________________________________________________________________________________________
                                                                          Addition to Tax
      Petitioner                       Docket No.  Year     Deficiency      Sec. 6653(b)
                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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