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ROSENBERG v. COMMISSIONER

Docket No. 8812-83.

54 T.C.M. 392 (1987)

T.C. Memo. 1987-441

Reuben Rosenberg and Michele G. Rosenberg v. Commissioner.

United States Tax Court.

Filed August 31, 1987.

Attorney(s) appearing for the Case

Paul C. Arshonsky, 120 S. LaSalle St., Chicago, Ill., Marvin Kamensky, and Michael A. Sandberg, for the petitioners. Andrew P. Fradkin, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined deficiencies, and an addition to tax, in petitioners' Federal income tax as follows:

                                  Addition to Tax
Taxable Year Ended   Deficiency   Section 6653(a)1

December 31, 1979   $59,186.00      $2,959.00
December 31, 1980    11,307.00       ------

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