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KELLEY v. COMMISSIONER

Docket Nos. 38520-84, 38521-84.

59 T.C.M. 206 (1990)

T.C. Memo. 1990-158

David M. Kelley and Mary L. Kelley v. Commissioner. David M. Kelley and Estate of Nancy I. Kelley, Deceased, David M. Kelley, Executor v. Commissioner.

United States Tax Court.

Filed March 26, 1990.

Attorney(s) appearing for the Case

Arthur H. Boelter and John J. White, Jr., 999 Third Ave., Seattle, Wash., for the petitioners. Michael McMahon and Dorinda J. Myers-Ohnstad, for the respondent.

Memorandum Findings of Fact and Opinion

GOLDBERG, Special Trial Judge:

These consolidated cases were assigned to Special Trial Judge Stanley J. Goldberg pursuant to 7456(d)(3) of the Internal Revenue Code of 1954 (redesignated section 7443A(b)(4) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2775) and Rule 180 et seq.1

Respondent determined the following...

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