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URANGA v. COMMISSIONER

Docket Nos. 6441-80, 9483-80.

46 T.C.M. 567 (1983)

T.C. Memo. 1983-373

Joel Uranga and Ann Uranga v. Commissioner.

United States Tax Court.

Filed June 22, 1983.

Attorney(s) appearing for the Case

Towner Leeper and David Leeper, for the petitioners. John F. Eiman, David W. Johnson, and Sheri A. Wilcox, for the respondent.

Memorandum Finding of Facts and Opinion

GOFFE, Judge:

In these consolidated cases, the Commissioner determined deficiencies in petitioners' Federal income taxes as follows:

     Year                 Deficiency

     1974 ............   $173,203.50
     1975 ............    119,764.70
     1976 ............     52,303.00

The issues for decision are (1) whether advances to Joel Uranga...

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