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WEBB v. COMMISSIONER

Docket Nos. 15858-89, 15859-89.

60 T.C.M. 1229 (1990)

T.C. Memo. 1990-581

Joyce E. Webb v. Commissioner. Charles L. Webb v. Commissioner.

United States Tax Court.

Filed November 13, 1990.

Attorney(s) appearing for the Case

Billy C. Burney, for the petitioners. J. Craig Young, for the respondent.

Memorandum Opinion

COUVILLION, Special Trial Judge:

These consolidated cases were instituted under section 7463.1 At trial, petitioners moved, under Rule 172(c), that the cases be considered under section 7443A(b)(3) and Rule 180 et seq. Petitioners' motions were granted.

Respondent determined deficiencies and additions to petitioners' Federal income taxes as follows:

                      Joyce E. Webb...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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