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BIAGIOTTI v. COMMISSIONER

Docket No. 12217-83.

52 T.C.M. 588 (1986)

T.C. Memo. 1986-460

Raymond Biagiotti and Mary Lou Biagiotti v. Commissioner.

United States Tax Court.

Filed September 22, 1986.

Attorney(s) appearing for the Case

William H. Kenety and Arthur Rosenberg, for the petitioners. Kenneth A. Hochman, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

On February 25, 1983, respondent issued a statutory notice of deficiency to petitioners determining the following deficiencies and additions to tax for the taxable years 1976 through 1980:

                                          Addition to Tax
   Year               Deficiencies        Section 6653(a)1

  1976 .................

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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