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STEEL v. COMMISSIONER

Docket Nos. 7859-85, 7860-85.

53 T.C.M. 816 (1987)

T.C. Memo. 1987-243

James M. Steel and Theresa B. Steel, et al. v. Commissioner.

United States Tax Court.

Filed May 11, 1987.

Attorney(s) appearing for the Case

Sam Dileo and C. Jerre Lloyd, for the petitioners. Timothy Burgmeier, for the respondent.

Memorandum Opinion

WHITAKER, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the years and in the amounts indicated:

Year                             Deficiency

1980 ..........................   $3,162.65
1981 ..........................    4,658.36

The issue for decision is whether petitioner James M. Steel (hereinafter referred to as petitioner or Steel) was physically present in...

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