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PRITCHETT v. COMMISSIONER

Docket Nos. 14586-81, 18127-81, 18128-81, 18477-81, 27413-82.

56 T.C.M. 1070 (1989)

T.C. Memo. 1989-21

Jerry E. Pritchett and Patricia D. Pritchett, et al. v. Commissioner.

United States Tax Court.

Filed January 11, 1989.

Attorney(s) appearing for the Case

Bruce I. Hochman, Martin N. Gelfand and Michael Constas, for the petitioners. Karl D. Zufelt and Steven M. Roth, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

This case is before the Court on remand from the Court of Appeals for the Ninth Circuit following appeal by petitioners from our opinion reported at 85 T.C. 580 (1985). Pritchett v. Commissioner [87-2 USTC ¶ 9517], 827 F.2d 644 (1987). In our original opinion we concluded that petitioners were not at risk within the meaning...

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