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PEARLSTEIN v. COMMISSIONER

Docket Nos. 5551-81, 5552-81.

58 T.C.M. 699 (1989)

T.C. Memo. 1989-621

Irving Pearlstein and Flora Pearlstein v. Commissioner. Allan H. Pearlstein v. Commissioner.

United States Tax Court.

Filed November 16, 1989.

Attorney(s) appearing for the Case

Stephen D. Gardner, John Hartje and Robert Lord, 1345 Avenue of the Americas, New York, N.Y., for the petitioner. Theodore J. Kletnick, Jo-Ann Fox and Susan Grossman, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In timely statutory notices of deficiency, respondent determined the following deficiencies in petitioners, 1974 Federal income taxes:

       Petitioners                         Docket No.    Deficiency

     Irving and Flora Pearlstein .......... 5551-81      $95,518.60
     Allan H. Pearlstein .................. 5552-81       93,710.00

At trial, respondent...

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