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MILLER v. COMMISSIONER

Docket No. 14856-81.

48 T.C.M. 409 (1984)

T.C. Memo. 1984-336

James E. Miller and Yvonne H. Miller v. Commissioner.

United States Tax Court.

Filed July 2, 1984.

Attorney(s) appearing for the Case

John P. Mahoney, for the petitioners. Carol A. Szczepanik, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined deficiencies in the amount of $7,257.00 and $5,235.00 in petitioners' joint 1976 and 1977 Federal income taxes. The sole issue for determination is whether petitioners are entitled to deductions under sections 7021 and 704 for specially allocated items from a partnership.

All of the facts have been stipulated, and are found accordingly. The...

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