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GRAEV v. COMMISSIONER

Docket No. 30638-08.

149 T.C. 485 (2017)

149 T.C. No. 23

LAWRENCE G. GRAEV AND LORNA GRAEV, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 20, 2017.

Attorney(s) appearing for the Case

Frank Agostino, Brian D. Burton, Jeremy M. Klausner, and Lawrence A. Sannicandro, for petitioners.

Shawna A. Early, for respondent.

SUPPLEMENTAL OPINION

By notice of deficiency issued pursuant to section 6212(a), respondent determined deficiencies in petitioners' income tax of $237,481 for 2004 and $412,620 for 2005.1 The deficiencies resulted from respondent's disallowance of both cash and noncash charitable contribution...

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