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PELHAM v. COMMISSIONER

Docket No. 3071-89.

66 T.C.M. 820 (1993)

T.C. Memo. 1993-441

Frank and Cynthia Pelham v. Commissioner.

United States Tax Court.

Filed September 21, 1993.

Attorney(s) appearing for the Case

Frank Pelham, Jr., and Cynthia D. Pelham, pro se. Patricia Anne Golembiewski and Susan Mosley, for the respondent.

Memorandum Findings of Fact and Opinion

PANUTHOS, Chief Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181 and 183.1

Respondent determined deficiencies in and additions to petitioners' Federal income tax for the taxable years 1985 and 1986 as follows:

                                                              Additions To Tax
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