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EVERETT v. COMMISSIONER

Docket Nos. 48539-86, 3375-87.

58 T.C.M. 1366 (1990)

T.C. Memo. 1990-65

Willis M. Everett III v. Commissioner. Neal M. Allen and Joan W. Allen v. Commissioner.

United States Tax Court.

Filed February 12, 1990.

Attorney(s) appearing for the Case

Kevin N. Kemp, James P. O'Neill and William O'C. Harnisch, 405 Lexington Ave., New York, N.Y., for the petitioners. Elizabeth P. Flores and Vincent J. Guiliano, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

In these consolidated cases, the Commissioner determined the following deficiencies in petitioners' Federal income tax and additions to tax for the taxable years and in the amounts as follows:


                                                                 Additions to Tax
                                                              ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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