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  5. 46 T.C.M. 458 (1983)
 

SIMMONS v. COMMISSIONER

Docket Nos. 24544-81, 9133-82.

46 T.C.M. 458 (1983)

T.C. Memo. 1983-349

William P. Simmons and Betty S. Simmons v. Commissioner. William P. Simmons and Betty S. Simmons, and Estate of David R. Simmons, Deceased (D.R. Simmons, Jr. and John M. Simmons, Co-Executors), and Ellen C. Simmons v. Commissioner of Internal Revenue.

United States Tax Court.

Filed June 14, 1983.

Attorney(s) appearing for the Case

William E. Nelson, Ralph B. Levy, and L. Joseph Loveland, 2500 Trust Co. Tower, Atlanta, Ga., for the petitioners. Stephen R. Klorfein, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

                    Docket
     Petitioners     No.     Year  Deficiency

William P. Simmons  9133-82  1975  $ 40,910.94
 and Betty S.       9133-82  1976    94,806.80
 Simmons           24544-81  1977    81,793.20
                    9133-82  1978   130,439.05

Estate of David R.  9133-82  1975    38...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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