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BEIERLE v. COMMISSIONER

Docket No. 3417-90.

63 T.C.M. 3010 (1992)

T.C. Memo. 1992-278

Dennis Allen Beierle and Diane Lorene Beierle v. Commissioner.

United States Tax Court.

Filed May 14, 1992.

Attorney(s) appearing for the Case

Dennis A. Beierle, pro se. Mary Ann Waters, for the respondent.

Memorandum Findings of Fact and Opinion

POWELL, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(4).1

By notice of deficiency, respondent determined deficiencies in petitioner's2 Federal income tax for the 1985 and 1986 taxable years in the respective amounts of $6,709 and $5,700. After concessions by petitioner,3 the only issues

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