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OURISMAN v. COMMISSIONER

Docket No. 4644-78.

82 T.C. 171 (1984)

FLORENZ R. OURISMAN AND BETTY JOAN OURISMAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 26, 1984.

Attorney(s) appearing for the Case

Lipman Redman, Jerry M. Hamovit, and Stephen D. Kahn, for the petitioners.

Joyce H. Errecart, for the respondent.

SIMPSON, Judge:

The Commissioner determined the following deficiencies in the petitioners' Federal income taxes:

Year                          Deficiency

1970 ........................ $95,183.04
1971 ........................ 998,554.81
1972 ........................  49,729.12

The issues for decision are: (1) Whether the losses generated by the construction and operation of...

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