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HERMAN v. COMMISSIONER

Docket No. 22676-81.

50 T.C.M. 1397 (1985)

T.C. Memo. 1985-557

Stanley I. Herman and Linda Herman v. Commissioner.

United States Tax Court.

Filed November 12, 1985.

Attorney(s) appearing for the Case

Philip S. Magaram and Jonathan A. Brod, 1880 Century Park East, Los Angeles, Calif., for the petitioners. Steven M. Roth, for the respondent.

Memorandum Opinion

FAY, Judge:

This case is before the Court on petitioners' motion for partial summary judgment pursuant to Rule 121.1 Respondent determined a deficiency of $158,198 in petitioners' Federal income tax for 1977. The notice of deficiency set forth seven adjustments to petitioners' income; two such adjustments, the decrease in the amount of capital gain and a corresponding increase in the amount of ordinary income...

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