QUANTZ v. COMMISSIONER

Docket No. 1188-83, 27712-83.

53 T.C.M. 1402 (1987)

T.C. Memo. 1987-358

Charles J. Quantz and Nancy Quantz v. Commissioner.

United States Tax Court.

Filed July 22, 1987.


Attorney(s) appearing for the Case

Charles J. Quantz, San Francisco, California, pro se. Theodore Garelis, for the respondent.


Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1978 and 1979 in the amounts of $162,296.95 and $79,544.00, respectively. In amended answers filed in each of these consolidated cases[,] respondent increased the deficiency for each year to $323,518 for 1978 and $372,668 for 1979.

After concessions by both parties, the issues for decision are (1) the...

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