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JACOBELLIS v. COMMISSIONER

Docket No. 34197-85.

55 T.C.M. 1317 (1988)

T.C. Memo. 1988-315

Benedict Jacobellis and Dolores Jacobellis v. Commissioner.

United States Tax Court.

Filed July 25, 1988.

Attorney(s) appearing for the Case

Lawrence A. Berger, for the petitioners. Catherine R. Chastanet, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:

                               Addition to Tax
Year              Deficiency   Sec. 6653(a)1

1976 ............   $25,586         $1,329
1977 ............     9,289            464
1978 ............     2,310            116

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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