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JACOBY v. COMMISSIONER

Docket No. 7073-87.

72 T.C.M. 1085 (1996)

T.C. Memo. 1996-477

Gerald Jacoby and Arlene Jacoby v. Commissioner.

United States Tax Court.

Filed October 23, 1996.

Attorney(s) appearing for the Case

Martin Rosen and L. William Fishman, for the petitioner Gerald Jacoby. Ira B. Stechel and Thomas J. Fleming, for the petitioner Arlene Jacoby. Diane Mirabito and Gary Bornholdt, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CLAPP, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

Year                                 Deficiency

1978 .............................     $93,098
1979 .............................      84,284
1980 .............................      28,675

Respondent also determined that petitioners are liable for increased interest pursuant to...

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