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LUIZ v. COMMISSIONER

Docket No. 6344-02.

87 T.C.M. 838 (2004)

T.C. Memo. 2004-21

Gary and Janet Luiz v. Commissioner.

United States Tax Court.

Filed January 29, 2004.

Attorney(s) appearing for the Case

Anthony V. Diosdi, for the petitioners.

Patricia Montero and Margaret S. Rigg, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge.

Respondent determined deficiencies in petitioners' Federal income tax of $47,116 for 1996 and $23,475 for 1997.1

Petitioner, a shareholder in Green Valley Sawmills, Inc. (Green Valley), an S corporation, guaranteed to creditors of Green Valley that he would repay Green Valley's debts if Green Valley did not repay them. After concessions, the sole issue for decision...

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