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McCLELLAND v. COMMISSIONER

Dkt. Nos. 1327-02, 1129-03.

89 T.C.M. 1329 (2005)

T.C. Memo. 2005-121

Eugene McClelland and Ione McClelland v. Commissioner.

United States Tax Court.

May 24, 2005.

Attorney(s) appearing for the Case

Paul V. Sween, for petitioner

Eugene McClelland; William A. Vincent, for petitioner

Ione McClelland; Blaine Holiday, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge:

By separate notices of deficiency, respondent determined deficiencies in petitioners' Federal income tax of $345,037 for the tax year 1997 and $97,037 for the tax year 1998. Petitioners timely petitioned the Court for redetermination of respondent's determinations in both notices, and the cases were consolidated. In a stipulation of settlement, the parties agreed to deficiencies of $265,255 for 1997 and...

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