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DELGADO v. COMMISSIONER

Docket No. 29240-83.

55 T.C.M. 155 (1988)

T.C. Memo. 1988-66

Felix Delgado and Rebecca Delgado v. Commissioner.

United States Tax Court.

Filed February 23, 1988.

Attorney(s) appearing for the Case

Moe D. Karash, 250 W. 57th St., New York, N.Y., for the petitioners. Alfred Pierri, Frank Agostino, and Alan G. Merkin, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

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

                                     Addition to Tax
Taxable Year Ended      Deficiency   Section 6653(b)1

December 31, 1973 ...     $7,578         $3,789
December 31, 1974 ...    $85,759        $42,880

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