Docket Nos. 22785-90, 22457-91.

72 T.C.M. 1270 (1996)

T.C. Memo. 1996-513

Jack J. Kramer v. Commissioner. Jack S. Kramer and Maxine C. Kramer v. Commissioner.

United States Tax Court.

Filed November 19, 1996.

Attorney(s) appearing for the Case

Sidney A. Soltz,2 for the petitioners. Stanley P. Kaplan,3 for the petitioner in Docket No. 22785-90. Kathleen L. Donohue, Ellen T. Friberg, and Eli J. Dicker, for the respondent.


BEGHE, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax for the taxable years 1985 to 1987 as follows:

1. Jack S. & Maxine C. Kramer—docket No. 22457-91

                                                                 Additions to Tax

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