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DOBRICH v. COMMISSIONER

Docket Nos. 3832-95, 7382-96.

74 T.C.M. 985 (1997)

T.C. Memo. 1997-477

David Dobrich and Naomi Dobrich v. Commissioner.

United States Tax Court.

Filed October 20, 1997.

Attorney(s) appearing for the Case

John M. Youngquist, San Francisco, Calif., and Donald L. Feurzeig, for the petitioners. Daniel J. Parent, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined deficiencies in petitioners' 1989 and 1990 Federal income tax in the amounts of $1,111,292 and $1,111,320, respectively, and section 6663(a)1 civil fraud penalties for 1989 and 1990 of $833,469 and $833,490, respectively. Respondent determined the income tax deficiency and penalty in the alternative for 1989 or 1990.

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