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SLATER v. COMMISSIONER

Docket No. 17646-84.

56 T.C.M. 1135 (1989)

T.C. Memo. 1989-35

Harold E. Slater, Jr. and Shirlee M. Slater v. Commissioner.

United States Tax Court.

Filed January 19, 1989.

Attorney(s) appearing for the Case

John F. Nolan, 24022 Calle De La Plata, Laguna Hills, Calif., for the petitioners. A. Lavar Taylor and Steven L. Staker, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

In a statutory notice of deficiency dated March 8, 1984, respondent determined deficiencies in petitioners' income taxes as follows:

  Year                       Deficiency

  1975...................... $ 23,917
  1977......................   29,321
  1978......................  134,550

The issues for our consideration involve the characterization of purported...

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