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PAOLI v. COMMISSIONER

Docket No. 33570-87.

62 T.C.M. 275 (1991)

T.C. Memo. 1991-351

Stephen A. Paoli and Betty Mae Paoli v. Commissioner.

United States Tax Court.

Filed July 31, 1991.

Attorney(s) appearing for the Case

William J. Gerard, for the petitioners. Teri A. Frank, for the respondent.

Memorandum Findings of Fact and Opinion

WHALEN, Judge:

Respondent determined the following deficiency in, and additions to, petitioners' 1982 Federal income tax:

                       Additions to tax under sections
Deficiency   6651(a)(1)   6653(a)(1)      6653(a)(2)      6661

 $34,780      $8,695       $1,739      50% of interest   $8,695
                                       due on $34,780
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