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GAVIOLA v. COMMISSIONER

Docket Nos. 6484-81, 3254-83.

52 T.C.M. 54 (1986)

T.C. Memo. 1986-349

David C. Gaviola and Helena M. Gaviola v. Commissioner. David C. Gaviola, deceased, and Helena M. Gaviola v. Commissioner.

United States Tax Court.

Filed August 5, 1986.

Attorney(s) appearing for the Case

I. Frederick Shotkin, for the petitioners. Lewis R. Mandel and Robert Schneps, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

This matter is before us on petitioner Helena Gaviola's motion to vacate two decisions of this Court, one entered on December 12, 1983 in docket number 3254-83 and the other entered on January 3, 1984 in docket number 6484-81.

In these consolidated cases, respondent determined deficiencies in petitioners' Federal income taxes as follows:

Taxable Year                       ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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