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ALLEN v. COMMISSIONER

Docket Nos. 39084-85, 11341-86.

53 T.C.M. 814 (1987)

T.C. Memo. 1987-242

Dean C. and Ehrentraud Allen v. Commissioner.

United States Tax Court.

Filed May 11, 1987.

Attorney(s) appearing for the Case

Charles F. Murray, for the petitioners. Marikay Lee-Martinez, for the respondent.

Memorandum Findings of Fact and Opinion

PAJAK, Special Trial Judge:

The proceedings in these cases were conducted pursuant to 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

In these consolidated cases, respondent determined deficiencies in each of petitioner's Federal income taxes and additions to taxes as follows:...

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