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MICHAELS v. COMMISSIONER

Docket No. 45700-86.

69 T.C.M. 3056 (1995)

T.C. Memo. 1995-294

Joseph M. Michaels and Vicki R. Michaels v. Commissioner.

United States Tax Court.

Filed June 29, 1995.

Attorney(s) appearing for the Case

Carleen L. Schreder and Michael von Mandel, for the petitioners. Joseph T. Ferrick, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

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

Year                                   Deficiency

1976 ...............................    $231,974
1979 ...............................      11,404
1980 ...............................     161,867

After concessions, the deficiency for the taxable year 1976 is $99,584, and there...

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