Docket Nos. 28233-91, 7795-94.

72 T.C.M. 1389 (1996)

T.C. Memo. 1996-529

Edward and Ruth Kelly v. Commissioner.

United States Tax Court.

Filed December 2, 1996.

Attorney(s) appearing for the Case

Geoffrey J. O'Connor, Garden City, N.Y., for the petitioner Edward Kelly. Norman Trabulus, for the petitioner Ruth Kelly. Andrew J. Mandell and Lewis J. Abrahams, for the respondent.


BEGHE, Judge:

Respondent determined deficiencies in petitioners'1 Federal income tax, additions to tax and penalties as follows:

                                                           Additions to Tax               Penalties

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