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PAREKH v. COMMISSIONER

Docket No. 21418-95.

75 T.C.M. 2181 (1998)

T.C. Memo. 1998-151

Manaharlal C. Parekh and Elizabeth Parekh v. Commissioner.

United States Tax Court.

Filed April 27, 1998.

Attorney(s) appearing for the Case

Michael D. Cropper, Midland, Tex., for the petitioners. Michael C. Prindible, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined deficiencies in petitioners' 1990 and 1991 Federal income taxes in the amounts of $117,021.24 and $12,343.39, respectively.

All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

The issues for decision are: (1) Whether petitioners are entitled to a deduction...

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