Bruno and Francesca Tabbi - Page 1

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                                 T.C. Memo. 1995-463                                  


                               UNITED STATES TAX COURT                                


                     BRUNO AND FRANCESCA TABBI, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      



               Docket No. 15863-93.     Filed September 28, 1995.                     


               Gerald J. Carnago, for petitioners.                                    
               Dennis G. Driscoll, for respondent.                                    


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

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