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WASSERSTROM v. COMMISSIONER

Docket No. 15943-81.

52 T.C.M. 392 (1986)

T.C. Memo. 1986-417

David E. Wasserstrom and Sandra R. Wasserstrom v. Commissioner.

United States Tax Court.

Filed September 4, 1986.

Attorney(s) appearing for the Case

Joseph E. Lundy, 20th Floor, Three Parkway, Philadelphia, PA. and Gerhart L. Klein, for the petitioners. Kenneth J. Rubin, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

By notice of deficiency dated April 6, 1981, respondent determined a deficiency in petitioners' 1977 Federal income tax in the amount of $250,487, and an addition to the tax pursuant to section 6653(a)1 in the amount of $12,524.

Petitioners attack the validity of the notice of deficiency, contending that respondent is barred...

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