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CHOU v. COMMISSIONER

Docket No. 20645-87.

58 T.C.M. 1496 (1990)

T.C. Memo. 1990-90

Jack C. Chou and Doris H. Chou v. Commissioner.

United States Tax Court.

Filed February 26, 1990.

Attorney(s) appearing for the Case

Warren Nemiroff, 2366 Roscomare Rd., Los Angeles, Calif., and Ronald D. Davis, for the petitioners. Debra Lynn Reale, for the respondent.

Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

The Commissioner determined a deficiency in petitioner's Federal income taxes in the amount of $38,447 for taxable year 1983. The Commissioner also determined additions to tax pursuant to sections 6653(a)(1),1 6653(a)(2), 6659 and increased interest pursuant to section 6621(c) for taxable year 1983.

The issues for decision are: (1) the fair market value of a carved...

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