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STEPHEN v. COMMISSIONER

Docket No. 17993-89.

64 T.C.M. 1357 (1992)

T.C. Memo. 1992-673

C. Stephen and Betty Boehm Babin v. Commissioner.

United States Tax Court.

Filed November 23, 1992.

Attorney(s) appearing for the Case

J. Timothy Bender, Aaron H. Bulloff, and Timothy J. O'Shaughnessy, 2112 E. Ohio Bldg., Cleveland, Ohio, for the petitioners. Jeffrey J. Erney, for the respondent.

Memorandum Findings of Fact and Opinion

WELLS, Judge:

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

Year                               Deficiency

1978 ...........................    $130,730
1979 ...........................     173,179
1982 ...........................      76,768

After concessions, we must decide several issues in the instant case. The first issue we must decide...

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