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SWARNER v. COMMISSIONER

Docket No. 12977-86.

64 T.C.M. 677 (1992)

T.C. Memo. 1992-519

Gene R. Swarner and Joyce C. Swarner; Key Maps, Incorporated v. Commissioner.

United States Tax Court.

Filed September 8, 1992.

Attorney(s) appearing for the Case

Declan J. O'Donnell, 6841 S. Yosemite St., Englewood, Colo., for the petitioners. Randall L. Preheim, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

This matter is before the Court on petitioners Swarner's motion for summary judgment filed pursuant to Rule 121.2 Respondent determined deficiencies in Gene R. and Joyce C. Swarner's (petitioners Swarner) Federal income taxes for the taxable years ending December 31, 1976, and December 31, 1979, in the amounts of $311 and $7,867, respectively.3

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