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PIEKOS v. COMMISSIONER

Docket Nos. 13007-80, 13008-80.

44 T.C.M. 1401 (1982)

T.C. Memo. 1982-602

Joseph S. Piekos v. Commissioner. Dolores F. Piekos v. Commissioner.

United States Tax Court.

Filed October 18, 1982.

Attorney(s) appearing for the Case

Arthur N. Nasser, 10 S. LaSalle St., Chicago, Ill., for the petitioners. Lawrence C. Letkewicz, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined a deficiency in petitioners' 1976 income tax of $27,111.60, and an addition to tax of $13,555.80 for civil fraud under section 6653(b).1 After concessions by both parties, two issues remain for our decision: (1) whether payments made by petitioner-husband's 50 percent-owner corporation for part of the construction costs of petitioners' personal residence...

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