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VESCO v. COMMISSIONER

Docket No. 8872-73.

39 T.C.M. 101 (1979)

T.C. Memo. 1979-369

Robert L. Vesco v. Commissioner.

United States Tax Court.

Filed September 11, 1979.

Attorney(s) appearing for the Case

Myles J. Sachs, Robert D. Foglia, and Joseph A. Foglia, for the petitioner. Agatha L. Vorsanger, William J. Salica, Bernard S. Mark and Joseph T. Chalhoub, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the calendar year 1971 in the amount of $775,310 and an addition to tax under section 6653(a), I.R.C. 1954,1 in the amount of $38,765.50.

The issues for decision are:

(1) Whether respondent's determination of deficiency in this case is arbitrary and capricious;

(2) whether petitioner...

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