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O'BRIEN v. COMMISSIONER

Docket Nos. 13923-82, 14682-82, 26246-83.

50 T.C.M. 417 (1985)

T.C. Memo. 1985-347

August J. Hoerrner v. Commissioner. Dennis R. O'Brien and Julia O'Brien v. Commissioner.

United States Tax Court.

Filed July 15, 1985.

Attorney(s) appearing for the Case

Jerome Kamerman and Steven Kamerman, 500 Fifth Ave., New York, N. Y., for the petitioner. Victoria Wilson, Jody Tancer and Alan H. Kaufman, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined deficiencies in the amount of $20,436.72 in petitioner August Hoerrner's ("Hoerrner") 1978 Federal income taxes.

Respondent determined deficiencies in the amount of $10,529.50 and $8,005.00, respectively, in petitioners Dennis and Julia O'Brien's1 ("O'Brien") joint 1978 and 1979 Federal income taxes.

The tax liabilities in dispute in...

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