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ROBERTS v. COMMISSIONER

Docket No. 21500-85.

53 T.C.M. 787 (1987)

T.C. Memo. 1987-235

William M. Roberts and Jean Albrecht Roberts v. Commissioner.

United States Tax Court.

Filed May 6, 1987.

Attorney(s) appearing for the Case

William M. Roberts, pro se. David R. Reid, for the respondent.

Memorandum Findings of Fact and Opinion

PAJAK, Special Trial Judge:

This case was heard pursuant to the provisions of section 7456(d) (redesignated as section 7443A(b) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq.1

Respondent has determined a deficiency in petitioners' Federal income taxes for 1980 and 1981 in the amount...

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