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DeVOE v. COMMISSIONER

Docket No. 29360-82.

52 T.C.M. 641 (1986)

T.C. Memo. 1986-477

Clayton E. DeVoe v. Commissioner.

United States Tax Court.

Filed September 24, 1986.

Attorney(s) appearing for the Case

J. Robert Riley, for the petitioner. R. Alan Lockyear, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

    Year Ended                  Deficiency

December 31, 1978 ............ $39,946.001
December 31, 1979 ............     744.00
December 31, 1980 ............  18,095.00

The primary issues for determination are (1) whether petitioner is entitled to...

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