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LARSEN v. COMMISSIONER

Docket No. 32893-83.

89 T.C. 1229 (1987)

VINCENT T. LARSEN AND LOUISE LARSEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 30, 1987.

Attorney(s) appearing for the Case

Thomas F. Topel, J. Marquis Eastwood, Kenneth L. Cutler, and Maureen H. Parkinson, for the petitioners.

Randall G. Durfee and Joel A. Lopata, for the respondent.

HAMBLEN, Judge:

Respondent determined deficiencies in petitioners'1 Federal income tax as follows:

Year                            Deficiency

1979 ..................................      $33,087
1980 ..................................       55,280

The primary issues for our determination are whether petitioner's transactions with respect to certain computer equipment were structured as a...

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