O'NEILL v. COMMISSIONER

Docket Nos. 18045-80, 29097-82.

49 T.C.M. 850 (1985)

T.C. Memo. 1985-92

John H. O'Neill and Marilyn S. O'Neill v. Commissioner.

United States Tax Court.

Filed February 28, 1985.


Attorney(s) appearing for the Case

Edward B. Simpson, 50 California St., San Francisco, Calif., for the petitioners. Edward I. Kaplan, for the respondent.


Memorandum Findings of Fact and Opinion

PETERSON, Special Trial Judge:

These consolidated cases were assigned to Special Trial Judge Marvin F. Peterson pursuant to the provisions of section 7456(c) and (d), and General Order No. 8, 81 T. C. XXIII (1983).

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

  Taxable Year                     Deficiency

     1976 ........................ $3,081.89
   ...

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