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LOCKWOOD v. COMMISSIONER

Docket No. 48476-86.

94 T.C. 252 (1990)

FRANK S. LOCKWOOD AND LINDA P. LOCKWOOD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 28, 1990.

Attorney(s) appearing for the Case

L. Guy Palmer, for the petitioners.

Janine M. Poronsky and James C. Lanning, for the respondent.

WILLIAMS, Judge:

The Commissioner determined deficiencies in petitioners' Federal income tax for the taxable years 1979 and 1980 in the amounts of $100,081 and $82,402, respectively. Respondent also determined increased interest pursuant to section 6621(c)1 for 1979 and 1980. After concessions, the only issues remaining are: (1) Whether petitioners are entitled to a deduction for retirement for their master recordings in 1979, and...

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