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ARNES v. COMMISSIONER

Docket No. 23291-91.

102 T.C. 522 (1994)

JOHN A. ARNES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 5, 1994.

Attorney(s) appearing for the Case

Darrell D. Hallett, for petitioner.

Lisa M. Oshiro, for respondent.

FAY, Judge:

This case is before the Court on the parties' cross-motions for summary judgment pursuant to Rule 121.1

By notice of deficiency dated October 8, 1991, respondent determined deficiencies in petitioner's Federal income taxes as follows:

   Year                                Deficiency

   1987 ............................   $42,725
   1988...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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