Docket No. 24583-93.

72 T.C.M. 301 (1996)

T.C. Memo. 1996-353

Angela Schwimmer v. Commissioner.

United States Tax Court.

Filed August 1, 1996.

Attorney(s) appearing for the Case

Robert D. Howard, New York, N.Y., for the petitioner. Catherine R. Chastanet and Peggy Gartenbaum, for the respondent.


SWIFT, Judge:

Respondent determined deficiencies in and additions to petitioner and her husband Martin J. Schwimmer's (Martin's) joint 1981, 1982, 1983, and 1984 Federal income taxes as follows:

                                                          Additions to Tax

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