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KEIL v. COMMISSIONER

Docket No. 15206-02.

89 T.C.M. 1026 (2005)

T.C. Memo. 2005-76

Johann Keil and Catherine Keil v. Commissioner.

United States Tax Court.

Filed April 7, 2005.

Attorney(s) appearing for the Case

Michael D. Stewart, Ronald A. Feuerstein, Candace M. Van den Bosch, and Gary H. Kuwada, for petitioners;

Elliot H. Kajan, for third party in interest Dwight M. Montgomery; Karen Nicholson Sommers, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION1

LARO, Judge:

Petitioners petitioned the Court to redetermine deficiencies of $862,621 and $1,528,818 in their Federal income taxes for 1993 and 1994, respectively, and related additions thereto totaling $389,285 and $688,169, respectively. On December 10, 2003, the parties filed with the Court a stipulation of settled issues (first stipulation of settled issues) that stated the...

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