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CIPPARONE v. COMMISSIONER

Docket No. 17364-81.

49 T.C.M. 1492 (1985)

T.C. Memo. 1985-234

Rocco C. Cipparone and Kathleen M. Cipparone v. Commissioner.

United States Tax Court.

Filed May 15, 1985.

Attorney(s) appearing for the Case

Howard Philip Newman, and Lowell E. Mann, for the petitioners. Russell K. Stewart and Paul J. Sude, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In a statutory notice dated April 15, 1981, respondent determined deficiencies in petitioners' Federal income tax liability and additions to tax as follows:

                                   Section 6653(b)1
    Year          Deficiency       Addition to Tax

    1974......... $   61.77          $   30.88
    19752 .......  1,247...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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