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GIALANELLA v. COMMISSIONER

Docket Nos. 4568-84, 4569-84.

51 T.C.M. 397 (1986)

T.C. Memo. 1986-44

Michael Gialanella and Nicolina Gialanella v. Commissioner. Italian Delight of Columbia Mall, Inc. v. Commissioner.

United States Tax Court.

Filed January 30, 1986.

Attorney(s) appearing for the Case

Andrew Jay Graham, Sun Life Building, Baltimore, Md., for the petitioners. John F. Dean, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

In these consolidated cases, respondent determined deficiencies and additions to tax under section 6653(b)1 for years and in amounts as follows:


           Michael Gialanella and Nicolina Gialanella, Docket No. 4568-84

  Year Ended                                                          Additions...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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