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MANFREDONIA v. COMMISSIONER

Docket No. 4127-68.

52 T.C. 207 (1969)

JOHN MANFREDONIA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 6, 1969.

Attorney(s) appearing for the Case

Joseph Aronstein, for the petitioner.

Marwin A. Batt, for the respondent.

OPINION

SCOTT, Judge:

On April 12, 1968, respondent mailed to petitioner a notice of deficiency for the taxable year ended December 31, 1964, determining a deficiency of $8,342.70 and an addition to tax under section 6653(a), I.R.C. 1954,1 of $417.13. The statement attached to the notice of deficiency showed an increase in petitioner's income by unreported partnership income of $20,000 from a 50-percent interest in a partnership...

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