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RYAN v. COMMISSIONER

Docket Nos. 461-96, 1274-96.

76 T.C.M. 453 (1996)

T.C. Memo. 1998-331

Frances J. Ryan v. Commissioner. W. Gregory and Patricia L. Ryan v. Commissioner.

United States Tax Court.

Filed September 21, 1996.

Attorney(s) appearing for the Case

Ross F. Stancati, Kalamazoo, Mich., for the petitioner in Docket No. 461-96. Daniel P. McGlinn, Russell A. Kreis, and Matthew S. DePerno for the petitioners in Docket No. 1274-96. Alexandra E. Nicholaides, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

DEAN, Special Trial Judge:

These cases were heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 These cases were consolidated on August 20, 1997, for purposes of trial, briefing, and opinion.

Respondent determined deficiencies in Frances J. Ryan's Federal income taxes for 1991, 1992, and 1993 in the amounts of $1,950, $1,950, and $1,950, respectively. Respondent...

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