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STARR v. COMMISSIONER

Docket No. 39314-84.

59 T.C.M. 161 (1990)

T.C. Memo. 1990-146

Erwin and Helen Starr v. Commissioner.

United States Tax Court.

Filed March 20, 1990.

Attorney(s) appearing for the Case

Richard J. Alan Cahan, 200 South Biscayna Blvd., Miami, Fla., for the petitioners. William C. Sabin, Jr., for the respondent.

Memorandum Opinion

BUCKLEY, Special Trial Judge:

We have before us petitioners' motion for summary judgment. This matter was assigned pursuant to the provisions of section 7443A of the Code.1

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

  Year                           Amount

  1978 .......................  $61,548
  1979 .......................   38...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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