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KATZ v. COMMISSIONER

Docket No. 6602-83.

90 T.C. 1130 (1988)

EDWARD AND PHYLLIS KATZ, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 15, 1988.

Attorney(s) appearing for the Case

Leonard A. Messinger and Mary J. Fahey, for the petitioners.

Jack H. Klinghoffer, Jane B. Wilson, and Stephen Ianello, for the respondent.

OPINION

WELLS, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for 1977 and 1978 in the amounts of $90,512 and $3,158, respectively. Respondent also determined that petitioner Edward Katz was liable for additions to tax pursuant to section 6653(b)1 for 1977 and 1978 in the amounts of $76,844 and $1,579, respectively. The issues for decision are (1) whether petitioners' reported gains and losses...

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