MARTUSCELLO v. COMMISSIONER

Memorandum Opinion

HOYT, Judge:

Respondent determined income tax deficiencies against petitioner Joseph Martuscello and, also, additions to tax under sections 291(a), 293(b), 294(d) (1)(A), and 294(d)(2) of the Internal Revenue Code of 1939, and sections 6653(b) and 6654 of the Internal Revenue Code of 1954, for the calendar years and in the amounts, as follows:

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