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D'ARCANGELO v. COMMISSIONER

Docket No. 22991-92.

68 T.C.M. 1223 (1994)

T.C. Memo. 1994-572

A. Rick and Marjorie E. D'Arcangelo v. Commissioner.

United States Tax Court.

Filed November 21, 1994.

Attorney(s) appearing for the Case

Laurence Keiser, for the petitioners. Gary Botwinick, for the respondent.

Memorandum Findings of Fact and Opinion

WELLS, Judge:

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

                        Additions to Tax
                    ------------------------
Year   Deficiency   Sec. 6659   Sec. 6621(c)

1986    $19,382       $5,194           1

1 120% of the interest...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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