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REYNOLDS v. COMMISSIONER

Docket No. 8087-84.

53 T.C.M. 887 (1987)

T.C. Memo. 1987-261

Harold M. Reynolds v. Commissioner.

United States Tax Court.

Filed May 26, 1987.

Attorney(s) appearing for the Case

Thomas A. Caldwell and Joanne C. Beckman, 450 Maclellan Building, Chattanooga, Tenn., for the petitioner. Vallie C. Brooks, for the respondent.

Memorandum Opinion

KÖRNER, Judge:

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

       Tax Year
        Ended                                 Deficiency

December 31, 1974 ......................... $ 28,790.00
December 31, 1977 .........................  380,364.501

After concessions by petitioner, the sole issue for decision is whether...

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