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BERTOLI v. COMMISSIONER

Docket No. 13648-92.

103 T.C. 501 (1994)

JOHN E. BERTOLI AND FRANCES BERTOLI, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 24, 1994.

Attorney(s) appearing for the Case

Frank J. Crupi, for petitioners.

Susan G. Lewis, Brendan G. King, and Guy G. Lavignera, for respondent.

OPINION

NIMS, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1986 and 1987 in the amounts of $195,221 and $9,041, respectively. Respondent further determined additions to tax for 1986 and 1987 under sections 6661 and 6653(a)(1)(A) and (B). Additionally, respondent determined an addition to tax for 1986 under section 6651(a)(1).

Unless otherwise indicated, all section references are to the...

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