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WILLINGER v. COMMISSIONER

Docket No. 26229-81.

45 T.C.M. 1069 (1983)

T.C. Memo. 1983-159

Albert J. Willinger and Dolores L. Willinger v. Commissioner.

United States Tax Court.

Filed March 23, 1983.

Attorney(s) appearing for the Case

Merrill E. Clements, 7940 LaRiviera, Sacramento, Calif., for the petitioners. Thomas M. Rohall, for the respondent.

Opinion

FAY, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

  Year             Deficiency

  1974 ........    $ 2,460.00
  1975 ........      2,891.00
  1976 ........      2,983.00
  1977 ........     12,637.00
  1978 ........      1,921.00

After concessions, the remaining issue is whether petitioners are entitled to a "new jobs" credit in connection with starting their own construction...

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