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INSOLERA v. COMMISSIONER

Docket No. 858-76.

36 T.C.M. 1734 (1977)

T.C. Memo. 1977-424

Roberto and Angela Insolera v. Commissioner.

United States Tax Court.

Filed December 15, 1977.

Attorney(s) appearing for the Case

Donald Israel, 230 Middle Neck Rd., Great Neck, N.Y., for the petitioners. Peter W. Mettler, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined the following deficiencies and additions to tax.

                              Additions to Tax
  Year             Deficiency    § 6653(b)

  1968 ........... $15,955.72    $7,977.86
  1969 ...........  11,426.25     5,713.13

The questions remaining for decision are as follows:

(1) Whether respondent correctly determined that petitioners...

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