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PARKS v. COMMISSIONER

Docket No. 571-70.

32 T.C.M. 175 (1973)

T.C. Memo. 1973-38

Frank Lloyd Parks v. Commissioner.

United States Tax Court.

Filed February 14, 1973.

Attorney(s) appearing for the Case

Eugene J. Moran, 150 Broadway, New York, N.Y., for the petitioner. H. Stephen Kesselman and Fred L. Baker, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined a deficiency in income tax and additions to the tax to be due from the petitioner for the taxable year 1964, as follows:

     Deficiency ............... $24,654.04
     Additions:

       Sec. 6651(a)1 .....   6,163.51
       Sec. 6653(a) ...........   1,232.70
       Sec. 6654 ..............     690.31

The issues presented...

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