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LAGERQUIST v. COMMISSIONER

Docket No. 1953-85.

53 T.C.M. 530 (1987)

T.C. Memo. 1987-185

George A. Lagerquist and Margaret E. Lagerquist v. Commissioner.

United States Tax Court.

Filed April 7, 1987.

Attorney(s) appearing for the Case

E.M. Murray and Matthew W. Stanley, 2200 First Interstate Plaza, Tacoma, Wash., for the petitioners. Michael R. McMahon, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

  Year                                Deficiency

  1977 .............................  $  1,531
  1978 .............................   597,269
  1979 .............................    18,200

After concessions, the issues for decision are (1) whether certain notes issued to petitioner...

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