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SUNDERMEIER v. COMMISSIONER

Docket No. 14512-84.

52 T.C.M. 1499 (1987)

T.C. Memo. 1987-50

Michael W. Sundermeier and Grace A. Sundermeier v. Commissioner.

United States Tax Court.

Filed January 22, 1987.

Attorney(s) appearing for the Case

Irving E. Fasan, for the petitioners. J. Anthony Hoefer, for the respondent.

Memorandum Opinion

BUCKLEY, Special Trial Judge:

The proceedings in this case were conducted pursuant to section 7456(d)(3) of the Code (redesignated sec. 7443A(b)(3) by sec. 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755)1 and Rules 180, 181 and 182, Tax Court Rules of Practice and Procedure.2

Respondent determined a deficiency in petitioners' 1980 Federal income tax in...

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