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KRAMER v. COMMISSIONER

Docket No. 26249-81.

56 T.C.M. 378 (1988)

T.C. Memo. 1988-475

David Kramer and Anita Kramer v. Commissioner.

United States Tax Court.

Filed September 28, 1988.

Attorney(s) appearing for the Case

Robert A. Shupack, for the petitioners. James R. Rich, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent, in a statutory notice of deficiency mailed July 24, 1981, determined income tax deficiencies in petitioners' 1977 and 1978 taxable years in the amounts of $17,709 and $20,304, respectively. The income tax deficiencies are substantially1 attributable to respondent's disallowance of petitioners' claimed losses and income tax credits from a truck leasing activity...

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