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WILHELM v. COMMISSIONER

Docket Nos. 15286-82, 23630-83.

51 T.C.M. 261 (1986)

T.C. Memo. 1986-12

Mary R. Wilhelm v. Commissioner. Mary Reed Wilhelm v. Commissioner.

United States Tax Court.

Filed January 13, 1986.

Attorney(s) appearing for the Case

Stephen Behrends, for the petitioner.1 Randall E. Heath, for the respondent.

Memorandum Findings of Fact and Opinion

PAJAK, Special Trial Judge:

These consolidated cases were heard pursuant to the provisions of section 7456 and Rule 180 et seq.2

Respondent determined deficiencies in petitioner's 1979 and 1980 Federal income taxes in the amounts of $3,778 and $2,122, respectively. After granting respondent's motion for partial summary judgment made at trial3 and concessions...

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