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FERACO v. COMMISSIONER

Docket Nos. 1759-99, 1760-99.

80 T.C.M. 463 (2000)

T.C. Memo. 2000-312

Frank J. & Ann M. Feraco v. Commissioner. Thomas M. Feraco v. Commissioner.

United States Tax Court.

Filed October 3, 2000.

Attorney(s) appearing for the Case

James L. McDonald, Sr., for the petitioners. Gwendolyn C. Walker, for the respondent.

MEMORANDUM OPINION

PAJAK, Special Trial Judge:

These cases have been consolidated for trial, briefing, and opinion. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue. Respondent determined the following deficiencies in Federal income taxes and penalties:

                                        6662(a)
                           Deficiency   Penalty

Frank J...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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