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FEIN-MARQUART ASSOCIATES, INC. v. COMMISSIONER

Docket No. 24809-82.

50 T.C.M. 152 (1985)

T.C. Memo. 1985-288

Fein-Marquart Associates, Inc., Ronald G. Marquart and Linda M. Marquart v. Commissioner.

United States Tax Court.

Filed June 17, 1985.

Attorney(s) appearing for the Case

Robert L. Flanagan and Robert A. Snyder, Jr., 100 S. Charles St., Baltimore, Md., for the petitioners. Robert A. Miller, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Chief Judge:

By notice of deficiency dated July 16, 1982, respondent determined that Fein-Marquart Associates, Inc., was liable for deficiencies in Federal income tax for the years 1978 and 1979 in the respective amounts of $6,421.50 and $3,527.01. By separate notice of deficiency dated the same date, respondent determined that Ronald G. Marquart and Linda M. Marquart were liable for deficiencies in

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