BIAGGI v. COMMISSIONER

Docket No. 16697-97.

79 T.C.M. 1488 (2000)

T.C. Memo. 2000-48

Mario Biaggi and Estate of Marie Biaggi, Deceased, Richard Biaggi, Executor v. Commissioner.

United States Tax Court.

Filed February 11, 2000.


Attorney(s) appearing for the Case

Leonard Bailin, for the petitioners. Drita Tonuzi and Daniel Rosen, for the respondent.


MEMORANDUM OPINION

HALPERN, Judge:

By notice of deficiency dated May 22, 1997, respondent determined deficiencies in, and additions to, petitioners' Federal income tax as follows:

                                                              Additions to Tax*
                                                   ---------------------------------------------
Year                                  Deficiency   Sec. 6653(b...

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