T.C. Memo. 1996-259
UNITED STATES TAX COURT
RICHARD H. DALEY AND ESTATE OF ANNE H. DALEY,
DECEASED, RICHARD H. DALEY, EXECUTOR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9816-93. Filed June 5, 1996.
Gregory A. Robinson, for petitioners.
Thomas S. Dileonardo, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge: Respondent determined deficiencies in, an
addition to, and penalties on petitioners’ Federal income taxes
as follows:1
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
(continued...)
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