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Petitioner John R. Wilson (Wilson), docket No. 3117-95
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(2) 6661
1982 $46,574 $23,287 1 $11,644
1983 59,924 29,962 1 14,981
1 Plus 50 percent of the interest due on the deficiency.
Petitioner James G. Cattalo (Cattalo), docket No. 3292-95
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(2) 6661
1982 $44,969 $22,485 1 $11,242
1983 77,862 38,931 1 19,466
1 Plus 50 percent of the interest due on the deficiency.
Petitioner David A. Grove (Grove), docket No. 3341-95
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(2) 6661
1982 $48,302 $24,151 1 $12,076
1983 85,674 42,837 1 21,419
1 Plus 50 percent of the interest due on the deficiency.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years before
the Court, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
The following issues are to be decided with respect to
Giongo, Wilson, Cattalo, and Grove:4
4 Ryan and respondent have entered into a stipulation of
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