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CARMEL v. COMMISSIONER

Docket No. 27300-89.

98 T.C. 265 (1992)

PETER W. CARMEL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 11, 1992.

Attorney(s) appearing for the Case

Ellis L. Reemer and Dennis M. Bresnan, for petitioner.

Sharon Katz-Pearlman and Gail A. Campbell, for respondent.

OPINION

CLAPP, Judge:

This case is before the Court on the parties' cross-motions for entry of decision. All section references are to the Internal Revenue Code for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Background

On August 15, 1989, respondent issued a notice of deficiency to petitioner and his wife for the taxable years...

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