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CROWELL v. COMMISSIONER

Docket No. 30831-83.

55 T.C.M. 1276 (1988)

T.C. Memo. 1988-305

Donald W. Crowell and Suzanne C. Crowell v. Commissioner.

United States Tax Court.

Filed July 20, 1988.

Attorney(s) appearing for the Case

William R. Nicholas, 555 S. Flower St., Los Angeles, Calif., Boyd J. Black, Thomas G. Bost, and John J. Clair, Jr., for the petitioners. Mark S. Priver, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

   Year                    Deficiency

  1975...................   $ 2,096
  1976...................   $ 5,555
  1977...................   $17,465
  1978...................   $56,370

The sole issue for decision is whether capital was a material income-producing factor in the brokerage...

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