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SIEGEL v. COMMISSIONER

Docket No. 14907-80.

50 T.C.M. 880 (1985)

T.C. Memo. 1985-441

David A. Siegel and Bettie I. Siegel v. Commissioner.

United States Tax Court.

Filed August 22, 1985.

Attorney(s) appearing for the Case

Paul H. Freeman, for the petitioners.1

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

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

Year                         Deficiency

1972 ........................ $15,768
1973 ........................   5,332
1974 ........................   2,898
1975 ........................     841
1976 ........................   3,898

The issues for decision are:

(1) Whether statutory...

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