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CHIPPI v. COMMISSIONER

Docket Nos. 3461-70, 3501-70, 3507-70.

30 T.C.M. 1014 (1971)

T.C. Memo. 1971-236

Peter Chippi and Mary M. Chippi, et al. v. Commissioner.

United States Tax Court.

September 15, 1971.

Attorney(s) appearing for the Case

Robert E. Teaford, 100 W. Broad, Columbus, Ohio, for the petitioners. Juandell D. Glass, for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The cases of these petitioners were consolidated for trial because similar proof and law is involved.

The Commissioner determined deficiencies in income tax of the petitioners and also penalties under section 6653(a), I. R. C. 1954,2 for negligence and intentional disregard of the income tax rules and regulations, as follows:

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