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ALBERT v. COMMISSIONER

Docket No. 4464-84.

52 T.C.M. 836 (1986)

T.C. Memo. 1986-517

Leslie and Frances Albert v. Commissioner.

United States Tax Court.

Filed October 20, 1986.

Attorney(s) appearing for the Case

James M. Allen and Gayle Nin Rosenkrantz, San Francisco, Calif., for the petitioners. James S. Daubney, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In a notice of deficiency dated November 17, 1983, respondent determined deficiencies in petitioners' Federal income tax liabilities for 1980 and 1981 in the following amounts:

  Year                           Deficiencies
  1980 ........................   $33,174
  1981 ........................    13,295

The sole issue for decision is whether certain amounts paid...

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