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MICHELSON v. COMMISSIONER

Docket Nos. 7250-94, 21182-94.

73 T.C.M. 1809 (1997)

T.C. Memo. 1997-39

Barry S. Michelson v. Commissioner. Shelley A. Michelson v. Commissioner.

United States Tax Court.

Filed January 22, 1997.

Attorney(s) appearing for the Case

Barry S. Michelson, pro se. Shelley A. Michelson, pro se. Carmino J. Santaniello, for the respondent.

MEMORANDUM OPINION

RAUM, Judge:

The Commissioner determined deficiencies in petitioners' 1991 Federal income taxes as follows:

Petitioner                                Deficiency   Sec. 6651(a)(1)   Sec. 6654(a)

Barry Michelson .......................    $   979        $  244.75           -0-
Shelley Michelson .....................     50,870         8,168.00         $1,450

Pursuant to respondent's...

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