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MALNIK v. COMMISSIONER

Docket No. 5307-76.

50 T.C.M. 977 (1985)

T.C. Memo. 1985-467

Alvin I. Malnik and Deborah C. Malnik v. Commissioner.

United States Tax Court.

Filed September 4, 1985.

Attorney(s) appearing for the Case

Steven S. Brown and Royal Martin, for the petitioners. Thomas R. Ascher, for the respondent.

Memorandum Opinion

DRENNEN, Judge:

By notice of the deficiency dated March 15, 1976, respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:

                              Addition to Tax
  Year        Deficiency         § 6653(b)1

  1962  ....  $323,254.66       $161,627.33
  1963  ....   625,279.29        312,639.65

The issues for decision are:

...

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