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KLAGSBRUN v. COMMISSIONER

Docket No. 21802-86.

55 T.C.M. 1519 (1988)

T.C. Memo. 1988-364

Samuel C. Klagsbrun and Francine Klagsbrun v. Commissioner.

United States Tax Court.

Filed August 10, 1988.

Attorney(s) appearing for the Case

William F. Conroy, 425 Park Ave., New York, N.Y., for the petitioners. Bruce Wilpon, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

   Year                    Deficiency

   1980 ...................  $24,649
   1981 ...................   56,999
   1982 ...................   35,351

Respondent also determined that, under section 6621(c),1 the deficiencies were substantial underpayments attributable...

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