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BROOKS v. COMMISSIONER

Docket No. 17552-90.

63 T.C.M. 3046 (1992)

T.C. Memo. 1992-295

Alan K. and Patti R. Brooks v. Commissioner.

United States Tax Court.

Filed May 19, 1992.

Attorney(s) appearing for the Case

Steven J. Cannata, for the petitioners. Robert W. Towler, for the respondent.

Memorandum Opinion

GOLDBERG, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1

Respondent determined deficiencies in petitioners' Federal income tax for the years 1980, 1981, and 1982 as follows:

                                                          Additions to Tax
Year                           Deficiency   ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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