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LEFKOWITZ v. COMMISSIONER

Docket No. 5985-80.

46 T.C.M. 485 (1983)

T.C. Memo. 1983-356

LeRoy M. Lefkowitz and Empire Systems, Inc. v. Commissioner.

United States Tax Court.

Filed June 16, 1983.

Attorney(s) appearing for the Case

Jay R. Ziegler, for the petitioners. Alan J. Pinner and Mary Schewatz, for the respondent.

Memorandum Findings of Fact and Opinion

RAUM, Judge:

The Commissioner determined the following income tax deficiencies:

Petitioner     Taxable Year Ended      Amount

LeRoy M. Lefkowitz ....  12-31-75      $ 21,809
                         12-31-76        19,764
Empire Systems, Inc. ..   5-31-74        46,800
                          5-31-75       106,408
                          5-31-76       106,800

After concessions, the...

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