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FRIEDLAND v. COMMISSIONER

Docket Nos. 18304-80, 21703-80.

44 T.C.M. 1192 (1982)

T.C. Memo. 1982-549

Harold Friedland and Elaine Friedland v. Commissioner. Robert S. Pollak and Joyce W. Pollak v. Commissioner.

United States Tax Court.

Filed September 22, 1982.

Attorney(s) appearing for the Case

Marvin Katz and Michael S. Gilinsky, Fifteenth Floor, The Fidelity Building, Philadelphia, Pennsylvania, for the petitioners in docket No. 18304-80. Robert M. Broder, Four Center Plaza, Philadelphia, Pennsylvania, for the petitioners in docket No. 21703-80. Russell K. Stewart, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent has determined a deficiency of $20,439 in petitioners Harold and Elaine Friedland's income tax for the calendar year 1974, and a deficiency of $16,479 in petitioners Robert and Joyce Pollak's income tax for that same year. Due to a concession by the Friedlands, $17,705 remains in dispute in docket No. 18304-80. At issue is whether payments Harold...

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