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HODGDON v. COMMISSIONER

Docket No. 21563-88.

98 T.C. 424 (1992)

WARNER W. HODGDON AND SHARON D. HODGDON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 8, 1992.

Attorney(s) appearing for the Case

Bruce I. Hochman, Dennis L. Perez, Steven R. Toscher, and Sanford Holo, for petitioners.

Sherri Spradley, for respondent.

OPINION

RAUM, Judge:

The Commissioner determined deficiencies in petitioners' income taxes as follows:

        TYE                                  Deficiency

    Dec. 31, 1980 ...........................  $222,493
    Dec. 31, 1981 ...........................   248,928
    Dec. 31, 1982 ...........................   183,465
    Dec. 31, 1983 ...........................    59,768

Petitioners resided in San...

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