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COLLETTI v. COMMISSIONER

Docket Nos. 3174-68, 2795-69.

33 T.C.M. 1211 (1974)

T.C. Memo. 1974-268

Bernard Colletti and Elsa Colletti v. Commissioner.

United States Tax Court.

Filed October 15, 1974.

Attorney(s) appearing for the Case

Jerome Kamerman, for the petitioners. Michael K. Phalin, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

The respondent determined the following deficiencies in petitioners' Federal income tax:

                                      Additions
                                       to Tax
Docket                               I. R. C. 1954
 No.       Year         Deficiency   Sec. 6653(b)

3174-68    1964 ....... $119,551.69   $59,775.85
2795-69    1965 .......   19,220.21     9,610.10
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