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FRANK v. COMMISSIONER

Docket Nos. 1856-78, 1857-78.

43 T.C.M. 1149 (1982)

T.C. Memo. 1982-214

Milton Frank and Josephine Frank v. Commissioner. Milton Frank v. Commissioner.

United States Tax Court.

Filed April 21, 1982.

Attorney(s) appearing for the Case

Murray Appleman, 225 Broadway, New York, N.Y., for the petitioners. Vincent R. Barrella and Michael K. Phalin, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:*

Respondent determined the following deficiencies in Federal income tax and additions to the tax for the years 1970 through 1973 against petitioner Milton Frank:

                               Additions to Tax
                             Sec.           Sec.
  Year        Deficiency    6651(a)1      6653(a)

  1970 ....... $37...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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