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DUBIN v. COMMISSIONER

Docket No. 23140-83.

52 T.C.M. 456 (1986)

T.C. Memo. 1986-433

Dale B. Dubin and Susan J. Dubin v. Commissioner.

United States Tax Court.

Filed September 11, 1986.

Attorney(s) appearing for the Case

Ralph A. Muoio and Scott D. Michel, One Thomas Circle N.W., Washington, D.C., and Mark T. Tate and E. Jackson Boggs, for the petitioners. James F. Kearney and Sara M. Coe, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In a statutory notice of deficiency dated June 30, 1983, respondent determined deficiencies in petitioners' Federal income tax liabilities, as follows:

  Years                           Deficiencies

  1978 ..............................   $ 97,324
  1979 ..............................    146,069
  1980 ..............................    142,170

The primary issue...

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