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RUSSO v. COMMISSIONER

Docket Nos. 7193-76, 5523-77.

39 T.C.M. 691 (1979)

T.C. Memo. 1979-497

Joseph E. Russo and Sally S. Russo v. Commissioner.

United States Tax Court.

Filed December 11, 1979.

Attorney(s) appearing for the Case

Melvin M. Engel, 2050 Houston Natural Gas Bldg., Houston, Tex. for the petitioners. William D. Peltz, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in the Federal income tax of petitioners as follows:

  Docket No.    Year     Deficiency

   7193-76      1970      $ 4,953
   7193-76      1971        9,295
   7193-76      1972       25,203
   5523-77      1973       20,460

Some of the issues raised by the pleadings have been disposed of by the parties, leaving

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