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UNIVERSITY CITY, INC. v. COMMISSIONER

Docket No. 3600-73.

38 T.C.M. 827 (1979)

T.C. Memo. 1979-198

University City, Inc. v. Commissioner.

United States Tax Court.

Filed May 21, 1979.

Attorney(s) appearing for the Case

Gary Randall and Thomas B. Tilford, Financial Center W. 717, Spokane, Wash. for the petitioner. Robert J. Chicoine and Darrell Hallett, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined deficiencies in petitioner's income taxes in the amounts of $13,602.79 and $16,773.59 for the taxable years 1969 and 1970, respectively. Petitioner filed a petition for the year 1970 only, instituting a refund suit in Federal District Court for the year 1969. Therefore, we have only 1970 before us.

The deficiencies are based primarily upon respondent's determination that...

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