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DIETRICK v. COMMISSIONER

Docket Nos. 13616-84, 42129-84.

55 T.C.M. 706 (1988)

T.C. Memo. 1988-180

Gerald Patrick Dietrick and Anita Lea Dietrick v. Commissioner.

United States Tax Court.

Filed April 28, 1988.

Attorney(s) appearing for the Case

Stephen A. Kappers, Florence, Ky., for the petitioners.1 Genevieve K. Murtaugh, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

In these consolidated cases, respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1980 and 1982 as follows:

  Docket No.          Year       Deficiency

  13616-84           1980         $70,864.55
  42129-84           1982          38,490.19

After a concession by petitioners, the issues for decision are:

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