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WIKSELL v. COMMISSIONER

Docket No. 11752-91.

75 T.C.M. 1512 (1998)

T.C. Memo. 1998-3

David L. Wiksell and Margaret Ann Carpender v. Commissioner.

United States Tax Court.

Filed January 5, 1998.

Attorney(s) appearing for the Case

Bruce I. Hochman, for the petitioner Margaret Ann Carpender. Steven M. Roth, for the respondent.

SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

NIMS, Judge:

This case is before the Court on remand from the Court of Appeals for the Ninth Circuit. Wiksell v. Commissioner [96-2 USTC ¶ 50,398], 90 F.3d 1459 (9th Cir. 1996), revg. and remanding [Dec. 49,713(M)] T.C. Memo. 1994-99.

Respondent has conceded all additions to tax as to petitioner Margaret Ann Carpender...

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