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CARLSON v. COMMISSIONER

Docket Nos. 29273-83, 35742-84.

53 T.C.M. 1176 (1987)

T.C. Memo. 1987-306

Robert O. Carlson and Eileen E. Carlson v. Commissioner.

United States Tax Court.

Filed June 23, 1987.

Attorney(s) appearing for the Case

Robert A. Trevisani and Arthur B. Crozier, for the petitioners. Anne Hintermeister and Dennis M. Bresnan, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' Federal income tax in these consolidated cases as follows:

    Year                      Amount

    1976 ..................  13,166.62
    1977 ..................  37,455.17
    1979 ..................  40,340.00

After concessions, the issues presented for decision are: (1) Whether petitioners are entitled...

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