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GUERCIO v. COMMISSIONER

Docket No. 4073-80.

43 T.C.M. 336 (1982)

T.C. Memo. 1982-28

Pasquale Guercio and Lydia Guercio v. Commissioner.

United States Tax Court.

Filed January 20, 1982.

Attorney(s) appearing for the Case

Arthur N. Nasser, 10 South La Salle St., Chicago, Ill., for the petitioners. Judith M. Picken, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $16,555 in petitioners' income tax for 1977, together with an addition to tax in the amount of $828 under section 6653(a).1 The principal issue for decision is the amount of petitioners' wagering income, if any, in 1977. Also for decision is whether petitioners' underpayment of tax, if any, was due to negligence or...

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