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GERHART v. COMMISSIONER

Docket Nos. 6299-82, 20551-85, 37767-85.

61 T.C.M. 1745 (1991)

T.C. Memo. 1991-35

James M. Gerhart and Phyllis Gerhart v. Commissioner.

United States Tax Court.

Filed January 29, 1991.

Attorney(s) appearing for the Case

James H. Vernon, for the petitioners. Steven M. Roth, for the respondent.

Memorandum Findings of Fact and Opinion

BUCKLEY, Special Trial Judge:

This case was heard pursuant to section 7443A(b) and Rules 180 et seq.1 In a notice of deficiency dated December 31, 1981, respondent determined the following deficiencies in petitioners' Federal income tax:

Year                              Deficiency

1974 ..........................     $3,097
1975 ................

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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