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KOZIARA v. COMMISSIONER

Docket Nos. 10828-80, 11321-80.

86 T.C. 999 (1986)

EUGENE H. KOZIARA AND LAURA A. KOZIARA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ANIELA KOZIARA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 21, 1986.

Attorney(s) appearing for the Case

Robert M. Justin, for the petitioners.

Clyde W. Mauldin, for the respondent.

OPINION

SWIFT, Judge:

This matter is before the Court on cross motions for summary judgment, filed October 19, 1984. These cases have been consolidated for purposes of trial, briefing, and opinion. The pertinent facts have been fully stipulated and are set forth below.

In separate statutory notices of deficiency dated April 7, 1980, respondent determined deficiencies in petitioners' Federal income...

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