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REICHENBACH v. COMMISSIONER

Docket Nos. 15915-94, 15916-94.

70 T.C.M. 313 (1995)

T.C. Memo. 1995-369

William C. Reichenbach v. Commissioner. Kathleen S. Reichenbach v. Commissioner.

United States Tax Court.

Filed August 7, 1995.

Attorney(s) appearing for the Case

Montfort S. Ray, for the petitioners. Peter M. Ritteman, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

The instant cases were consolidated for purposes of trial, briefing, and opinion. William C. Reichenbach and Kathleen S. Reichenbach (petitioners) separately petitioned the Court to redetermine respondent's determination of deficiencies in, and additions to, their 1991 and 1992 Federal income taxes. Respondent determined the following deficiencies in Federal income tax and additions thereto:

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