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ZARIN v. COMMISSIONER

Docket No. 21371-86.

92 T.C. 1084 (1989)

DAVID ZARIN AND LOUISE ZARIN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 22, 1989.

Attorney(s) appearing for the Case

Karl William Kolbe, Jr., and David R. Hardy, for the petitioners.

Patricia Y. Taylor, for the respondent.

OPINION

COHEN, Judge:

Respondent determined deficiencies of $2,466,622 and $58,688 in petitioners' Federal income taxes for 1980 and 1981, respectively.

In the notice of deficiency, respondent determined that petitioners had income in 1980 from larceny by trick and deception. Respondent has abandoned that position. All of the other issues raised in the notice of deficiency have been settled. In his...

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