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SPARKS v. COMMISSIONER

Docket No. 42022-85.

87 T.C. 1279 (1986)

FRANK D. SPARKS AND EMILY J. SPARKS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 8, 1986.

Attorney(s) appearing for the Case

Robert E. Kovacevich, for the petitioners.

Eileen Kato Player, for the respondent.

WILLIAMS, Judge:*

This case is before the Court on respondent's motion to sever from the petition the adjustments relating to the Project Omega Limited Partnership that resulted in a portion of the deficiency determined by respondent in Federal income tax for petitioners' taxable year 1982.

The Commissioner determined deficiencies in petitioners' Federal income tax for the taxable...

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