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SPAGNUOLO v. COMMISSIONER

Docket Nos. 6754-82, 9234-82.

50 T.C.M. 1281 (1985)

T.C. Memo. 1985-528

Joseph D. Spagnuolo and Julie Spagnuolo v. Commissioner.

United States Tax Court.

Filed October 9, 1985.

Attorney(s) appearing for the Case

Carolyn M. Conway and Francis J. DiMento, 100 State St., Boston, Mass., for the petitioners. Paul J. Dee, Jr. and Albert A. Balboni, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

These cases have been consolidated for purposes of trial, briefing and opinion. Respondent determined deficiencies and additions to tax as follows:

                                    Addition to Tax
    Year           Deficiency         Sec. 6653(b)

    1974 ........  $14,813.36         $ 7,406.68
    1975 ........   67,233.04          33,616.52
    1976 ........   62,343.10       ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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