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MOORE v. COMMISSIONER

Dkt. No. 11002-03.

93 T.C.M. 1275 (2007)

T.C. Memo. 2007-134

Barry E. Moore and Deborah E. Moore v. Commissioner.

United States Tax Court.

May 30, 2007.

Attorney(s) appearing for the Case

Vivian D. Hoard and Patti M. Richards, for petitioners.

Michael L. Scheier and Jennifer J. Morales, for affected person United Surgical Partners International, Inc.

Brenda M. Fitzgerald, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge:

By notice of deficiency dated April 10, 2003 (the notice), respondent determined deficiencies in petitioners' Federal income tax as follows:

    Year           Deficiency

    1999             $96,925
    2000              78,578

By the petition, petitioners assign error to respondent's deficiency determination...

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