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KESSLER v. COMMISSIONER

Docket Nos. 5846-75, 5847-75.

36 T.C.M. 514 (1977)

T.C. Memo. 1977-117

Philip W. Kessler and Ellen J. Kessler v. Commissioner. Aecco, Incorporated v. Commissioner.

United States Tax Court.

Filed April 25, 1977.

Attorney(s) appearing for the Case

Charles L. Howard, III, for the petitioners. Frank Simmons, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes and additions to the tax as follows:

Philip W. Kessler and Ellen J. Kessler

                             Additions to Tax
  Year       Deficiency     Under Sec. 6653(b)1

  1966 ....  $   495.33         $  247.66
  1967 ....   13,767...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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