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STARR v. COMMISSIONER

Docket No. 39314-84.

62 T.C.M. 1417 (1991)

T.C. Memo. 1991-610

Erwin Starr and Helen Starr v. Commissioner.

United States Tax Court.

Filed December 10, 1991.

Attorney(s) appearing for the Case

Richard J. Alan Cahan, 2699 S. Bayshore Dr., Miami, Fla., and Joshua N. Bennett, for the petitioners. W. Robert Abramitis and John F. Hernandez, for the respondent.

Memorandum Opinion

HALPERN, Judge:

By notice of deficiency dated September 7, 1984, respondent determined deficiencies in petitioners' Federal income tax as follows:

Tax Year Ending                     Deficiency

December 31, 1978 ...............    $61,548
December 31, 1979 ...............     38,539
December 31, 1980 ...............     67,936

By amendment to his answer, respondent also determined that petitioners...

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