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RHEINSTROM v. COMMISSIONER

Docket No. 7853-76.

43 T.C.M. 668 (1982)

T.C. Memo. 1982-101

Carroll Rheinstrom and Estate of Irene Rheinstrom, Deceased, Carroll Rheinstrom and the Bank of New York, Executors v. Commissioner.

United States Tax Court.

Filed February 25, 1982.

Attorney(s) appearing for the Case

John E. Beerbower, One Chase Manhattan Plaza, New York, N.Y., for the petitioners. Joan Ronder Domike, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined deficiencies in Federal individual income tax against petitioners as follows:1

  Year            Deficiency

  1967........... $ 9,753.64
  1968...........  20,429.22
  1970...........  30,557.60
  1971...........  32,963.00
  1972...........  38,000.14

Petitioners claim an overpayment for 1967 of not less than $319.25,...

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