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GAMBINA v. COMMISSIONER

Docket No. 32716-85.

91 T.C. 826 (1988)

FILIPPO GAMBINA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 20, 1988.

Attorney(s) appearing for the Case

Robert F. Katzberg, for the petitioner.

Vallerie Volesko and Nancy Chassman Rothbaum, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $71,460.40 in petitioner's Federal income tax for 1984, an addition to tax of $7,146.04 under section 6651(a)(1),1 an addition to tax of $3,573 under section 6653(a)(1), and an addition to tax under section 6653(a)(2) in the amount of 50 percent of the interest due on the underpayment.

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