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ALLEN v. COMMISSIONER

Docket Nos. 8114-71, 8210-71.

34 T.C.M. 242 (1975)

T.C. Memo. 1975-39

Raymond L. Allen and Shirley L. Allen v. Commissioner. Sportcraft Homes, Inc. v. Commissioner.

United States Tax Court.

Filed February 27, 1975.

Attorney(s) appearing for the Case

Michel G. Emmanuel and Michael D. Annis, 20th Floor, Exchange Nat'l Bldg., 610 Florida Ave., Tampa, Fla., for the petitioners. W.P. White, for the respondent.

Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined the following deficiencies and penalties against Raymond and Shirley Allen for the following years:

  Calendar                   Section 6653 (a)1
   Year          Deficiency     Penalty

   1967 ......  $  24,209.27  $  1,210.46
   1968 ......  2,014,056.46   100,702.82
   1969 ......    115,325.21     5,766.26
               _____________...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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