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ROSE v. COMMISSIONER

Docket No. 25635-83.

88 T.C. 386 (1987)

JAMES L. ROSE AND JUDY S. ROSE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 5, 1987.

Attorney(s) appearing for the Case

Robert L. Ackerson and Steven A. Goodman, for the petitioners.

Albert Russo, William S. Garofalo, and Matthew Magnone, for the respondent.

COHEN, Judge:

Respondent determined deficiencies of $191,335 and $302,451.12 in petitioners' Federal income taxes for 1979 and 1980, respectively. The issues for determination are (1) whether petitioners are entitled to depreciation and miscellaneous deductions and investment tax credit in relation to their purchase from Jackie Fine Arts of photographic transparencies of Picasso paintings and related production rights; (2) whether petitioners are entitled to...

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