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POLIZZI v. COMMISSIONER

Docket Nos. 52715, 52716.

16 T.C.M. 668 (1957)

T.C. Memo. 1957-159

Charles A. Polizzi and Angela Polizzi, Husband and Wife v. Commissioner. Charles A. Polizzi v. Commissioner.

United States Tax Court.

Filed August 14, 1957.

Attorney(s) appearing for the Case

Arlene B. Steuer, Esq., and Michael E. Cozza, Esq., for the petitioners. James F. Shea, Esq., and John K. Lynch, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

ATKINS, Judge:

The respondent determined deficiencies in income tax of Charles Polizzi, and additions thereto under the specified sections of the Internal Revenue Code of 1939, for the years and in the amounts as follows:

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