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BURTON v. COMMISSIONER

Docket Nos. 12970-90, 12971-90.

99 T.C. 622 (1992)

FRANCIS C. BURTON, JR., AND HELEN H. BURTON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 17, 1992.

Attorney(s) appearing for the Case

Marquis E. Whittington, for petitioners.

Ansley N. Acree, for respondent.

HAMBLEN, Chief Judge:

Respondent determined deficiencies in petitioners' 1985 and 1986 Federal income tax in the respective amounts of $74,904.30 and $40,585.81. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the taxable years at issue, and Rule references are to the Tax Court Rules of Practice and Procedure.

The sole issue for decision is whether petitioners properly...

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