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LEVINE v. COMMISSIONER

Docket No. 34405-87.

70 T.C.M. 283 (1995)

T.C. Memo. 1995-362

Stanley and Phyllis Levine v. Commissioner.

United States Tax Court.

Filed August 2, 1995.

Attorney(s) appearing for the Case

Gino Pulito, for the petitioners. John Aletta, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

ARMEN, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b) and Rules 180 et seq.1

Respondent determined deficiencies in, and additions to, petitioners' Federal income taxes for taxable years 1980, 1981, and 1983 as follows:

                                                         Additions to Tax
                       ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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