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THEOPHILOS v. COMMISSIONER

Docket No. 8450-91.

67 T.C.M. 2106 (1994)

T.C. Memo. 1994-45

Anthony Theophilos and Patricia A. Theophilos v. Commissioner.

United States Tax Court.

Filed February 7, 1994.

Attorney(s) appearing for the Case

Martin A. Schainbaum1, 580 California St., San Francisco, Calif., and Donald R. Share, One Market Plaza, San Francisco, Calif., for the petitioners.* Mary Wynne, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

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

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

1986   $1,819.630     $90,981.50    $454.907.50
1987       10,862         --     ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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