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MOZAYENY v. COMMISSIONER

Docket No. 32423-83.

53 T.C.M. 566 (1987)

T.C. Memo. 1987-188

Manouchehr Mozayeny and Shirin Mozayeny v. Commissioner.

United States Tax Court.

Filed April 9, 1987.

Attorney(s) appearing for the Case

Allen C. Clarke, 1440 N. Harbor Blvd., Fullerton, Calif., for the petitioners. Carolyn R. Bechman, for the respondent.

Memorandum Findings of Fact and Opinion

BUCKLEY, Special Trial Judge:

This case was heard pursuant to the provisions of 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) and Rules 180, 181 and 182.1

Respondent determined a deficiency in petitioner's 1980 Federal income tax in the amount of...

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