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CARLEBACH v. COMMISSIONER

Docket No. 19291-10.

139 T.C. 1 (2012)

LEAH M. CARLEBACH AND URIEL FRIED, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 19, 2012.

Attorney(s) appearing for the Case

Elissa F. Borges, Saul B. Abrams, and Stuart M. Schabes, for petitioners.

Stephen C. Huggs and Jeffrey E. Gold, for respondent.

HALPERN, Judge:

This case involves two notices of deficiency (together, notices). By the first notice, respondent determined deficiencies, additions to tax, and penalties with respect to petitioners' joint Federal income tax, as follows:

                        Addition to tax       Penalty
Year     Deficiency     sec. 6651(a)(1)     sec. 6662(a)

2004       $4,696            $424               $939
...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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