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  5. 40 T.C.M. 941 (1980)
 

HIGLEY v. COMMISSIONER

Docket Nos. 5808-76, 5809-76.

40 T.C.M. 941 (1980)

T.C. Memo. 1980-306

Sterling F. Higley and Jane N. Higley v. Commissioner. Frank Z. Higley and Barbara M. Higley v. Commissioner.

United States Tax Court.

Filed August 11, 1980.

Attorney(s) appearing for the Case

Frederick J. Martin, 2 William St., White Plains, N.Y., for the petitioners. Peter W. Mettler, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for 1974 as follows:

Docket No.                               Deficiency

  5808-76    Sterling F. and
               Jane N. Higley ............  $21,331
  5809-76    Frank Z. and
               Barbara M. Higley .........   15,267

The only issue presented for our consideration in these consolidated cases...

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