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FACUSEH v. COMMISSIONER

Docket No. 28579-82.

54 T.C.M. 1489 (1988)

T.C. Memo. 1988-10

Elias Facuseh and Margarita Facuseh v. Commissioner.

United States Tax Court.

Filed January 6, 1988.

Attorney(s) appearing for the Case

David Garvin, 2250 S.W. 3rd Ave., Miami, Fla., for the petitioners. Mitchell Horowitz, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

By notice dated September 20, 1982, respondent determined a deficiency in petitioners' Federal income tax for 1981 in the amount of $422,219. Respondent also determined an addition to tax under section 6653(a)(1)1 of $21,111.2 After concessions, the remaining issues are: (1) whether petitioners have $446,000 of unreported income in 1981; (2...

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