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ESTATE OF YAEGER v. COMMISSIONER

Docket No. 20514-83.

55 T.C.M. 1101 (1988)

T.C. Memo. 1988-264

Estate of Louis Yaeger, Deceased, Judith Winters, Raphael Meisels, Abraham K. Weber, and The Bank of New York, Executors v. Commissioner.

United States Tax Court.

Filed June 21, 1988.

Attorney(s) appearing for the Case

Richard A. Levine, Sidney I. Roberts and John M. Graham, 30 Rockefeller Plaza, New York, N.Y., for the petitioners. Jack H. Klinghoffer and Sandy E. Freund, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

By a notice of deficiency dated April 15, 1983, respondent determined deficiencies in Louis and Betty Yaeger's Federal income tax for the taxable years 1979 and 1980 in the amounts of $936,755 and $611,796, respectively.1

After concessions,2 the sole issue for our consideration is whether Yaeger was engaged in a trade or business with...

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