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BRAIN v. COMMISSIONER

Docket Nos. 39472-86, 39565-86.

58 T.C.M. 1249 (1990)

T.C. Memo. 1990-35

Irving H. Brain, Jr. and Kathleen B. Brain v. Commissioner.

United States Tax Court.

Filed January 22, 1990.

Attorney(s) appearing for the Case

John E. Cicero II and Terrence F. Pyle, 707 Franklin St., Tampa, Fla., for the petitioners. Monica J. Miller, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In timely notices of deficiency, respondent determined deficiencies in petitioners' Federal income taxes for 1982, 1983, and 1984, additions to tax, and additions to interest as follows:

                           Petitioners Irving and Kathleen Brain
                                    Docket No. 39472-86

                                             Additions to Tax or...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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