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RIFKIN v. COMMISSIONER

Docket No. 15233-96.

75 T.C.M. 2294 (1998)

T.C. Memo. 1998-180

Stephen H. Rifkin and Pamela T. Rifkin v. Commissioner.

United States Tax Court.

Filed May 13, 1998.

Attorney(s) appearing for the Case

Warren Nemiroff, Los Angeles, Calif., for the petitioners. Miles D. Friedman, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined Federal income tax deficiencies in petitioners'1 1992 and 1993 taxable years as follows:

                                         Penalties
                                           Sec.
Year                        Deficiency    6662(a)

1992 ....................     $23,257     $4,651
1993 .........

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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