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CHES v. COMMISSIONER

Docket No. 6120-75.

35 T.C.M. 1750 (1976)

T.C. Memo. 1976-387

Bernard J. Ches and Rose Ches v. Commissioner.

United States Tax Court.

Filed December 16, 1976.

Attorney(s) appearing for the Case

Allen L. Schwait, 1001 Keyser Bldg., Baltimore, Md., and L. Paige Marvel, for the petitioners. Robert B. Perry, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

Respondent determined a deficiency in petitioners' federal income tax liability for the calendar year 1971 in the amount of $49,856.94. He also determined that petitioners are liable for an addition to tax pursuant to section 6653(b), I.R.C. 19541 in the amount of $24,928.47.

The issues for decision are: (1) whether respondent's determination of the amount of gambling...

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