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O'HERON v. COMMISSIONER

Docket No. 13220-79.

42 T.C.M. 1628 (1981)

T.C. Memo. 1981-648

Clarence J. O'Heron and Helen F. O'Heron v. Commissioner.

United States Tax Court.

Filed November 5, 1981.

Attorney(s) appearing for the Case

Joseph G. Kohler and Kurtis A. Greenley, 4200 IDS Center, Minneapolis, Minn., for the petitioners. Jeffrey D. Lerner, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined a deficiency in petitioners' income tax for the taxable year 1974 in the amount of $47,695, together with an addition to such tax under section 6653(a) of the Internal Revenue Code of 1954, as amended,1 in the amount of $2,425. Many of the issues have been settled by the parties. The remaining issues for decision are:

(1) whether petitioner...

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