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GERARD v. COMMISSIONER

Docket No. 344-01, 346-01.

86 T.C.M. 604 (2003)

T.C. Memo. 2003-320

Damian Gerard and Leigh H. Gerard v. Commissioner. Peter W. Hobler and Katherine A. Hobler v. Commissioner.

United States Tax Court.

Filed November 20, 2003.

Attorney(s) appearing for the Case

Richard D. Lageson and Brenda L. Talent, for the petitioners.

Michael W. Bitner and Steven W. LaBounty, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

THORNTON, Judge:

In these consolidated cases, respondent determined deficiencies in petitioners' 1994 Federal income taxes as follows:


  Petitioners                 Deficiency
  Peter and Katherine Hobler    $188,518
  Damian and Leigh Gerard        100,704

In the course of a family shareholder dispute, Bill Maritz, who was chairman and chief executive...

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