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  5. 103 T.C. 634 (1994)
 

CHILDS v. COMMISSIONER

Docket Nos. 15639-92, 15640-92, 16256-92, 16257-92.

103 T.C. 634 (1994)

RICHARD A. CHILDS, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 14, 1994.

Attorney(s) appearing for the Case

Jacob Beil, for petitioners in docket Nos. 15639-92 and 15640-92.

Richard A. Childs, for petitioner in docket No. 15640-92.

Sylvia K. Kochler and Patrick G. Jones, for petitioners in docket Nos. 16256-92 and 16257-92.

Lourdes M. DeSantis, Amy A. Campbell, and Charles P. Hanfman, for respondent.

SCOTT, Judge:

Respondent determined deficiencies in petitioners Richard A. Childs' and Mimi P. Childs' income tax for the taxable years 1986 and 1987 in the amounts of $37,176.42 and $34,792.85, respectively, and additions to tax under section 66612 for the taxable years 1986 and 1987 in the amounts of $9,294 and $8,698, respectively. Respondent determined deficiencies in the income tax...

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