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SALVA v. COMMISSIONER

Docket No. 9255-91.

65 T.C.M. 2080 (1993)

T.C. Memo. 1993-90

Pedro and Concepcion Salva v. Commissioner.

United States Tax Court.

Filed March 16, 1993.

Attorney(s) appearing for the Case

Joaquin N. Fernandez, 2601 S. Bayshore Dr., Coconut Grove, Fla., for the petitioners. James P. Dawson, for the respondent.

Memorandum Opinion

HALPERN, Judge:

By notice of deficiency dated March 12, 1991, respondent determined a deficiency and additions to tax for petitioners' 1987 taxable year as follows:

                               Additions to Tax
             ---------------------------------------------------
Deficiency   Sec. 6653(a)(1)(A)   Sec. 6653(a)(1)(B)   Sec. 6661

$237,821          $11,891         50% of interest...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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