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GILBERT v. COMMISSIONER

Docket No. 9528-82.

53 T.C.M. 461 (1987)

T.C. Memo. 1987-165

Michael Gilbert and Sandra Gilbert v. Commissioner.

United States Tax Court.

Filed March 26, 1987.

Attorney(s) appearing for the Case

Richard B. Wallace, William H. Karo, and Theodore Brill, 25 W. Flagler St., Miami, Fla., for the petitioners. James W. Clark, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Chief Judge:

Respondent determined, by notice of deficiency dated March 24, 1982, deficiencies in the Federal income taxes of petitioners Michael Gilbert and Sandra Gilbert for the taxable years ended December 31, 1975 through December 31, 1977, as follows:

  Taxable
  Year                          Deficiency

  1975 ......................    $72,724
  1976 .............

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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