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CAPPETTA v. COMMISSIONER

Docket No. 10534-82.

49 T.C.M. 785 (1985)

T.C. Memo. 1985-76

Robert Cappetta and Seena Cappetta v. Commissioner.

United States Tax Court.

Filed February 21, 1985.

Attorney(s) appearing for the Case

Leonard M. Simon, for the petitioners. Laurence D. Ziegler and Thaddeus G. Wozny, for the respondent.

Memorandum Opinion

GERBER, Judge:*

Respondent determined deficiencies in Federal income tax against petitioners Robert Cappetta and Seena Cappetta for the years 1974, 1975, and 1976. Petitioners filed joint returns for those years. Respondent, for the same taxable years, also determined additions to tax under section 6653(b)1 against petitioner2 Robert Cappetta only. The...

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