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CLOUD v. COMMISSIONER

Docket No. 1107-73.

35 T.C.M. 95 (1976)

T.C. Memo. 1976-27

Earl E. Cloud and Marjorie B. Cloud v. Commissioner.

United States Tax Court.

Filed February 2, 1976.

Attorney(s) appearing for the Case

Earl E. Cloud, pro se, 1307 Stonehurst Dr., S.E., Huntsville, Ala. Roy S. Fischbeck, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1968 and 1969 in the amounts of $4,618.68 and $2,437.48, respectively.

The issues for decision are:

(1) Whether petitioners are collaterally estopped by the opinion and decision of this Court in Earl E. Cloud [Dec. 32,604(M)], T.C. Memo. 1974-131, involving...

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