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MATCHINSKE v. COMMISSIONER

Docket No. 22194-86.

53 T.C.M. 1211 (1987)

T.C. Memo. 1987-309

Dolph F. Matchinske and Marilyn R. Matchinske v. Commissioner.

United States Tax Court.

Filed June 23, 1987.

Attorney(s) appearing for the Case

Christopher M. Laquer, 3055 Wilshire Blvd., Los Angeles, Calif., for the petitioners. Joyce L. Sugawara, for the respondent.

Memorandum Opinion

GERBER, Judge:

Petitioners, on December 23, 1986, moved to amend their petition in this case and respondent objected.1 The issue presented is whether the petition placed in issue all taxable years which were set forth in the statutory notice of deficiency. If we find that any of the taxable years in the statutory notice were not petitioned, we would not have...

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