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WHELPLEY v. COMMISSIONER

Docket Nos. 21644-93, 21690-93.

73 T.C.M. 2367 (1997)

T.C. Memo. 1997-142

William Whelpley, Jr. v. Commissioner. William and Sara Whelpley v. Commissioner.

United States Tax Court.

Filed March 18, 1997.

Attorney(s) appearing for the Case

Alan L. Frank and David Kessler, Philadelphia, Pa., for the petitioners. David Breen and Kenneth J. Rubin, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHALEN, Judge:

Respondent determined the following deficiencies in, additions to, and penalties on petitioners' Federal income tax for the years in issue:

William Whelpley, Jr., Docket No. 21644-93:

                                                         Addition to Tax    Penalty
Year                                        Deficiency      Sec. 6653      Sec...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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