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WESTPHAL v. COMMISSIONER

Docket No. 7237-93.

68 T.C.M. 1038 (1994)

T.C. Memo. 1994-537

Lester R. and Marjorie L. Westphal v. Commissioner.

United States Tax Court.

Filed October 25, 1994.

Attorney(s) appearing for the Case

Joseph P. Alexander and Stephen L. Kadish, 2112 E. Ohio Bldg., Cleveland, Ohio, for the petitioners. Anita A. Gill, for the respondent.

Memorandum Opinion

COUVILLION, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Respondent determined, for petitioners' 1989 and 1990 tax years, respectively, deficiencies in Federal income taxes of $3,214.73 and $4,924.07.

The sole issue for decision is whether the activity of Marjorie L. Westphal (petitioner...

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