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GUADERRAMA v. COMMISSIONER

Docket Nos. 16255-97, 20939-97.

79 T.C.M. 1752 (2000)

T.C. Memo. 2000-104

Lauro G. and Gayle W. Guaderrama v. Commissioner. Steve H. Benavidez v. Commissioner.

United States Tax Court.

Filed March 28, 2000.

Attorney(s) appearing for the Case

Towner Leeper, for the petitioners in Docket No. 16255-97. Ramon Acosta, for the petitioner in Docket No. 20939-97. Rosemary Schell, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

In separate notices of deficiency, respondent took a protective position and determined deficiencies in petitioners' Federal income taxes as follows:

Docket No.   Year   Deficiency

16255-97     1993    $35,452
             1994     17,053

20939-97     1992    112,339
             1993      1,054

1 This amount...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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