Docket No. 26636-87.

72 T.C.M. 675 (1996)

T.C. Memo. 1996-425

Charles L. Fields and Barbara S. Fields v. Commissioner.

United States Tax Court.

Filed September 19, 1996.

Attorney(s) appearing for the Case

Lawrence F. Ruggiero and Robert Koppelman, for the petitioners.1

Cheryl A. Mclnroy, Elizabeth A. Maresca, and Steven D. Tillem, for the respondent.


LARO, Judge:

Charles L. Fields and Barbara S. Fields petitioned the Court to redetermine respondent's determinations with respect to their 1980 through 1982 taxable years. Respondent determined deficiencies of $525,389, $243,493, and $1,365 in their 1980, 1981, and 1982 Federal income taxes, respectively. Respondent also determined that Mr. Fields was liable for a: (1) $262...

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