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WINN v. COMMISSIONER

Docket Nos. 5358-96, 5359-96.

73 T.C.M. 3167 (1997)

T.C. Memo. 1997-286

Philip D. and Eleanor G. Winn v. Commissioner. David A. and Louise A. Gitlitz v. Commissioner.

United States Tax Court.

Filed June 24, 1997.

Attorney(s) appearing for the Case

Darrell D. Hallett, Seattle, Wash., Larry N. Johnson, Robert J. Chicoine, and John M. Colvin, for the petitioners. Keith G. Medleau, for the respondent.

MEMORANDUM OPINION

COHEN, Chief Judge:

Respondent determined a deficiency of $242,555 in Philip D. and Eleanor G. Winn's (the winns) 1992 Federal income tax and a deficiency of $251,192 in David A. and Louise A. Gitlitz's (the Gitlitzes) 1991 Federal income tax. The issue for decision is whether Philip D. Winn (Winn) and David A. Gitlitz (Gitlitz) are entitled to claimed S corporation losses of approximately $1 million, which in turn depends upon whether...

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