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WOLFF v. COMMISSIONER

Docket No. 13142-89.

67 T.C.M. 2875 (1994)

T.C. Memo. 1994-196

Jonathan P. Wolff and Margaret A. Wolff v. Commissioner.

United States Tax Court.

Filed May 2, 1994.

Attorney(s) appearing for the Case

Herbert Stoller and William L. Bricker, Jr., 101 Park Ave., New York, N.Y., for the petitioners. Steven R. Guest and Mark J. Miller, for the respondent.

Memorandum Opinion

PANUTHOS, Chief Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1

Respondent determined deficiencies in petitioners' Federal income tax as follows:

Year                                   Deficiency

1979 ...............................    $55,114
1980 ...............................    $82,369
1981 ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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