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DiLEO v. COMMISSIONER

Docket Nos. 22366-86, 22367-86, 15778-87.

58 T.C.M. 304 (1989)

T.C. Memo. 1989-540

Joseph R. DiLeo and Mary A. DiLeo, et al. v. Commissioner.

United States Tax Court.

Filed September 28, 1989.

Attorney(s) appearing for the Case

Jared J. Scharf and Morton A. Smith, 11 Martine Ave., White Plains, N.Y., for the petitioners. Christopher B. Sterner, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Chief Judge:

These consolidated cases are before us on petitioners' motion to suppress evidence on the grounds that respondent obtained certain grand jury materials in violation of Rule 6(e), Federal Rules of Criminal Procedure (Rule 6(e)).

Respondent determined the following deficiencies in and additions to petitioners' Federal income tax:

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