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MULDERIG v. COMMISSIONER

Docket No. 5978-92.

67 T.C.M. 2474 (1994)

T.C. Memo. 1994-123

William M. Mulderig and Joan G. Mulderig v. Commissioner.

United States Tax Court.

Filed March 28, 1994.

Attorney(s) appearing for the Case

William M. Mulderig, pro se.

Raymond A. Kahn and Gregory Nickerson, for the respondent.

Memorandum Findings of Fact and Opinion

LARO, Judge.

William M. Mulderig and Joan G. Mulderig (petitioners) petitioned this Court for redetermination of respondent's determinations reflected in her notice of deficiency. Respondent determined a deficiency of $1,055,581 in petitioners' 1982 Federal income tax, and an addition to such tax under section 6653(a)1 in the amount of $52,779.

The issues for decision are: (1) Whether...

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