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HOULBERG v. COMMISSIONER

Docket No. 16766-82.

50 T.C.M. 1125 (1985)

T.C. Memo. 1985-497

Jens P. Houlberg and Jane Houlberg v. Commissioner.

United States Tax Court.

Filed September 23, 1985.

Attorney(s) appearing for the Case

Ronald K. Van Wert, 4041 MacArthur Blvd., Newport Beach, Calif., for the petitioners. James M. Kamman, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

By statutory notice, respondent determined the following deficiencies in petitioners' Federal income tax:

      Year               Deficiency
      1976 .............. $7,443
      1977 ..............  5,553
      1978 ..............  3,276
      1979 ..............  9,895

The issues for decision are (1) whether the period of limitations on assessment for 1976 and 1977 was...

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