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CARTER v. COMMISSIONER

Docket Nos. 9515-74, 10470-75.

37 T.C.M. 859 (1978)

T.C. Memo. 1978-202

Charles H. Carter and Virgie Ann Carter v. Commissioner.

United States Tax Court.

Filed May 31, 1975.

Attorney(s) appearing for the Case

William E. Coombs, 225 S. Riverside Ave., Rialto, Calif., for the petitioners. George W. McDonald and W. Winter Nesbitt III, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' Federal income tax as follows:

  Docket No.    Year                  Deficiency

    9515-74     1971 ...............  $1,218.20
                1972 ...............   2,788.97
   10470-75     1973 ...............   8,444.98

The issues remaining for decision are whether petitioners: (1) were engaged in the trade or business...

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