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PATRICK v. COMMISSIONER

Docket No. 22034-96.

75 T.C.M. 2309 (1998)

T.C. Memo. 1998-183

Patrick F. and Arlene G. Sheehy v. Commissioner.

United States Tax Court.

Filed May 18, 1998.

Attorney(s) appearing for the Case

Ralph C. Larsen, for the petitioners. Christine V. Olsen, for the respondent.

MEMORANDUM OPINION

RAUM, Judge:

The Commissioner determined deficiencies of $31,643 and $1,605 in petitioners' 1992 and 1993 Federal income taxes, respectively. At issue is whether petitioners are entitled to deduct an expenditure of $50,000 in connection with their investment in Recyclable Containers Company. This case was submitted on the basis of a stipulation of facts.

Petitioners, Patrick and Arlene Sheehy, resided in California when the petition...

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