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  5. 46 T.C.M. 388 (1983)
 

RUSSO v. COMMISSIONER

Docket Nos. 24781-81, 5017-82.

46 T.C.M. 388 (1983)

T.C. Memo. 1983-324

Courtney L. and Percilla M. Russo v. Commissioner. Joseph P. Licciardi, Jr. v. Commissioner.

United States Tax Court.

Filed June 7, 1983.

Attorney(s) appearing for the Case

John A. Stassi II and Edward N. George III, 810 Union St., New Orleans, La. 70112, for the petitioners. H. Karl Zeswitz, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income taxes in the amounts and for the taxable years as follows:

                                     Year   Deficiency

  Courtney L. Russo and Percilla     1978    $1,590.19
    M. Russo .....................   1979     2,934.81
  Joseph P. Licciardi, Jr.........   1978     2,973.83

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