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ENGEL v. COMMISSIONER

Docket No. 48140-86.

55 T.C.M. 303 (1988)

T.C. Memo. 1988-94

Daniel and Elaine Engel v. Commissioner.

United States Tax Court.

Filed March 2, 1988.

Attorney(s) appearing for the Case

Daniel R. Engel, pro se. Michael A. Urban, for the respondent.

Memorandum Findings of Fact and Opinion

GUSSIS, Special Trial Judge:

This case was heard pursuant to the provisions of section 7456(d)(3) of the Internal Revenue Code (redesignated section 7443A(b)(3) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq. of the Tax Court Rules of Practice and Procedure.1

Respondent determined deficiencies in petitioners' Federal income taxes...

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