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ANGELL v. COMMISSIONER

Docket No. 17556-83.

52 T.C.M. 939 (1986)

T.C. Memo. 1986-528

Joseph S. Angell and Patricia E. Angell v. Commissioner.

United States Tax Court.

Filed October 27, 1986.

Attorney(s) appearing for the Case

Thomas C. Baratta, Jr., for the petitioners. Andrew P. Fradkin and Mark L. Cohen, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined deficiencies in petitioners' income tax and additions to tax as follows:

  Calendar                        Addition to Tax
    Year             Deficiency   Section 6653(b)1
  1973 .............  $34,477          $17,238
  1974 .............   58,504           29,252
  1975 .............   52,011...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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