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POWELL v. COMMISSIONER

Docket No. 4565-83.

49 T.C.M. 540 (1985)

T.C. Memo. 1985-27

David J. Powell and Estate of Jeane D. Powell, Deceased, David J. Powell, Executor v. Commissioner.

United States Tax Court.

Filed January 14, 1985.

Attorney(s) appearing for the Case

Claude R. Wilson, Jr. and William S. Lee, 2300 Republic Bank Tower, Dallas, Tex., for the petitioners. David A. Hampel, for the respondent.

Memorandum Opinion

DAWSON, Chief Judge:

This case is before the Court on petitioners' motion for an award of litigation costs which was filed on July 30, 1984, pursuant to Rule 231.1

Respondent determined a deficiency of $12,240.53 in petitioners' Federal income tax for the taxable year 1977. The adjustments that gave rise to the deficiency are described in the notice of deficiency as follows:


                        

                            

                                
                            

                            

                                

                                    
    
                                        
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