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MICHEL v. COMMISSIONER

Docket No. 10537-87.

58 T.C.M. 1019 (1989)

T.C. Memo. 1989-670

William H. Michel and Joyce A. Michel v. Commissioner.

United States Tax Court.

Filed December 26, 1989.

Attorney(s) appearing for the Case

Henry G. Alexander, Jr., 1900 Fifth Third Center, Cincinnati, Ohio, for the petitioners. Robin Herrell, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

By notice of deficiency dated January 29, 1987, respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1983 in the amount of $322. By amended answer, respondent increased petitioners' deficiency to $4,918.82, consisting entirely of the section 4973(a) excise tax.1 After concessions,2 the issues for decision...

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