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FIRETAG v. COMMISSIONER

Docket No. 4021-97.

78 T.C.M. 645 (1999)

T.C. Memo. 1999-355

Philip L. Firetag v. Commissioner.

United States Tax Court.

Filed October 25, 1999.

Attorney(s) appearing for the Case

Irvin J. Slotchiver, Charleston, S.C., for the petitioner. James E. Gray, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GALE, Judge:

Respondent determined the following deficiencies in petitioner's Federal income tax:

Year                               Deficiency

1992 ...........................    $219,032
1993 ...........................      46,944

After concessions, we must decide the following: (1) Whether petitioner is required to recognize as income in the years in issue amounts deposited...

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