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DIRECTOR v. COMMISSIONER

Docket Nos. 15877-84, 15878-84.

55 T.C.M. 1059 (1988)

T.C. Memo. 1988-256

Nathan Director v. Commissioner. Nathan Director and Anne Director v. Commissioner.

United States Tax Court.

Filed June 13, 1988.

Attorney(s) appearing for the Case

Robert Katz, 66 North Village Ave., Rockville Centre, N.Y., and Edwin A. Bernstein, for the petitioners. Lewis R. Mandel and Rose E. Gole, for the respondent.

Memorandum Opinion

WRIGHT, Judge:

These consolidated cases are before the Court on petitioners' motions to suppress evidence and for summary judgment, filed pursuant to Rule 121.1 Respondent has submitted written notices of objection to these motions.

By separate notices of deficiency dated March 6, 1984, respondent determined the following deficiencies and additions to tax in petitioners' Federal income tax:

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