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CARTER v. COMMISSIONER

Docket Nos. 17951-83, 7071-84.

51 T.C.M. 1082 (1986)

T.C. Memo. 1986-214

Jay Carter and Joan H. Carter v. Commissioner.

United States Tax Court.

Filed May 28, 1986.

Attorney(s) appearing for the Case

Peter R. Stromer, 15951 Los Gatos Blvd., Los Gatos, Calif., for the petitioners. M. Kendall Williams, for the respondent.

Memorandum Opinion

NIMS, Judge:

These cases are before the Court on respondent's motion for imposition of sanctions pursuant to Rule 104(c).1 Oral arguments on this motion were heard on November 13, 1985, at San Francisco, California.

In notices of deficiency mailed to petitioners bearing the dates of April 15, 1983, and March 2, 1984, respondent determined deficiencies in and additions to petitioners' Federal income...

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