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LOMANGINO v. COMMISSIONER

Docket No. 17489-80.

53 T.C.M. 1270 (1987)

T.C. Memo. 1987-322

Nicholas J. Lomangino v. Commissioner.

United States Tax Court.

Filed June 25, 1987.

Attorney(s) appearing for the Case

John R. Serpico, for the petitioner. Kevin M. Flynn, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined that petitioner was subject to additions to tax under section 6653(b)1 in the amounts of $2,822.00, $5,962.00 and $6,483.00 for the taxable years 1971, 1972 and 1973 respectively.

The sole issue for decision is whether petitioner's conceded omission of distributable income from a subchapter S corporation was due to fraud.

Findings of...

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