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GMELIN v. COMMISSIONER

Docket Nos. 3673-85, 3831-85.

55 T.C.M. 1410 (1988)

T.C. Memo. 1988-338

Lenz W. Gmelin and Ingeborg U. Gmelin v. Commissioner.

United States Tax Court.

Filed July 29, 1988.

Attorney(s) appearing for the Case

Donald A. Richards, 80 Main St., West Orange, N.J., for the petitioners. Caroline R. Ades, Edward G. Martoglio, and Frank Agostino for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

In a notice of deficiency dated November 30, 1984, respondent determined deficiencies in petitioners' Federal income tax for the years and in the amounts as follow:

   Year                    Amount

   1979 ..................  $624,106
   1980 ..................   725,024

Respondent's answers assert that the deficiencies constitute substantial underpayments...

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