T.C. Memo. 1996-529
UNITED STATES TAX COURT
EDWARD AND RUTH KELLY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 28233-91, 7795-94. Filed December 2, 1996.
Geoffrey J. O'Connor, for petitioner Edward Kelly,
Norman Trabulus, for petitioner Ruth Kelly.
Andrew J. Mandell and Lewis J. Abrahams, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge: Respondent determined deficiencies in
petitioners'1 Federal income tax, additions to tax and penalties
as follows:
1During preparation of this opinion, counsel for petitioner
Ruth Kelly informed the Court of his client's death. A motion to
substitute her estate as petitioner had not been received as of
the date of this opinion.
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