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ZIMMERMAN v. COMMISSIONER

Docket No. 4661-85.

54 T.C.M. 927 (1987)

T.C. Memo. 1987-534

Abraham Zimmerman and Marilyn Zimmerman v. Commissioner.

United States Tax Court.

Filed October 20, 1987.

Attorney(s) appearing for the Case

William Randolph Klein, 2071 Main St., Sarasota, Fla., for the petitioners. Avery B. Cousins III and Steven A. Wilson, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined the following deficiencies in the petitioners' Federal income taxes:

Year                             Deficiency

1979 .........................   $ 3,482.34
1980 .........................    33,143.46
1981 .........................    98,406.34

The issues for decision are: (1) Whether the petitioners are entitled for 1979 to a deduction...

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