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METRO LEASING AND DEVELOPMENT CORPORATION v. COMMISSIONER

Docket Nos. 8054-99, 8055-99.

81 T.C.M. 1644 (2001)

T.C. Memo. 2001-119

Metro Leasing and Development Corporation, East Bay Chevrolet Company, A Corporation v. Commissioner.

United States Tax Court.

Filed May 18, 2001.

Attorney(s) appearing for the Case

William L. Raby, for the petitioners.

Kathryn K. Vetter, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

In these consolidated cases, respondent determined the following deficiencies and penalties in petitioners'1 1995 and 1996 taxable years:

                                            Deficiencies  
                                   Income        Accumulated           Penalty
   Year                         ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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