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FERRELL v. COMMISSIONER

Docket Nos. 8679-86, 8742-86, 7283-87.

90 T.C. 1154 (1988)

WILLIAM L. FERRELL, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 16, 1988.

Attorney(s) appearing for the Case

Michael J. Christianson, for the petitioners.

William H. Quealy, Jr., and Jeffrey A. Hatfield, for the respondent.

FEATHERSTON, Judge:

These consolidated actions are test cases which were selected for trial to attempt to resolve approximately 200 other cases (many with multiple petitioners) docketed in this Court, as well as other similar cases pending administratively in the Internal Revenue Service (IRS). In the cases before the Court, respondent determined the following deficiencies for 1981 and 1982:


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