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FERGUSON v. COMMISSIONER

Docket No. 31491-83.

53 T.C.M. 864 (1987)

T.C. Memo. 1987-257

Howard E. Ferguson v. Commissioner.

United States Tax Court.

Filed May 21, 1987.

Attorney(s) appearing for the Case

John Kennedy Lynch, for the petitioner. Richard S. Bloom, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

    Taxable Year Ended               Deficiency

    December 31, 1976 .............. $346,525
    December 31, 1977 ..............   33,235

After concessions,1 the sole issue for determination is whether...

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