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TSCHETTER v. COMMISSIONER

Docket Nos. 5271-01, 5272-01.

86 T.C.M. 639 (2003)

T.C. Memo. 2003-326

Robert W. Tschetter, v. Commissioner. Wolf Creek Farm, Inc., v. Commissioner.

United States Tax Court.

Filed November 25, 2003.

Attorney(s) appearing for the Case

Douglas Bleeker, for the petitioners.

Douglas Polsky and Charles Berlau, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

These cases have been consolidated for trial, briefing, and opinion. In separate notices of deficiency, respondent determined deficiencies in petitioners' Federal income tax and accuracy-related penalties under section 66621 for 1995, 1996, and 1997 as follows:

Robert W. Tschetter, Docket No. 5271-01:

          Year   Deficiency
          ----...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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