SUNA v. COMMISSIONER

Docket Nos. 12212-86, 12407-86, 12427-86, 12487-86, 12504-86.

56 T.C.M. 720 (1988)

T.C. Memo. 1988-541

Irwin M. Suna and Suzann S. Suna, et al. v. Commissioner.

United States Tax Court.

Filed November 29, 1988.


Attorney(s) appearing for the Case

Mark B. Cohn and Daniel R. McCarthy, 55 Public Square, Cleveland, Ohio, for the petitioners. Susan M. Gray, for the respondent.


Memorandum Findings of Fact and Opinion

GERBER, Judge:

In these consolidated proceedings, respondent, by statutory notices, determined deficiencies in petitioners' Federal income taxes for calendar year 1982, as follows:

                                                      Additions to Tax
                                      -------------------------------------------
   Petitioners       Deficiency       6653(a)...

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