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PORRECA v. COMMISSIONER

Docket No. 13858-83.

86 T.C. 821 (1986)

JOSEPH PORRECA AND JOSEPHINE PORRECA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 28, 1986.

Attorney(s) appearing for the Case

Michael I. Saltzman, William T. Holloran, and Paul J. Green, for the petitioners.

Laurence D. Ziegler and Rona Klein, for the respondent.

SWIFT, Judge:

In a statutory notice dated March 9, 1983, respondent determined deficiencies in petitioners' Federal income tax liabilities as follows:

Year                              Amount

1979 ......................... $61,617.33
1980 ......................... 115,490.00
1981 .........................  30,738.82

The primary issues for decision are: (1) Whether petitioner Joseph Porreca was at risk within the meaning...

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