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12. whether the Michoff, Srs., substantially understated
their tax in the 1986 and 1987 tax years.
Issues With Respect to Michoff, Jr., and Kimberly Michoff
13. Whether Michoff, Jr., received unreported income in the
1986, 1987, 1988, and 1989 tax years in the amounts of $39,850,
$29,879, $24,422, and $68,798, respectively;
14. whether the Michoff, Jrs., had unreported taxable
income in the 1990 tax year in the amount of $22,649;
15. whether Michoff, Jr., realized a capital gain from the
sale of a partnership interest in the 1986 tax year in the amount
of $26,058;
16. whether Michoff, Jr., is entitled to any Schedule C
deductions with regard to a limousine activity for his 1989 tax
year;
17. whether Michoff, Jr., failed to timely file his Federal
income tax returns for the 1986 and 1987 tax years;
18. whether Michoff, Jr., failed to pay estimated tax for
the 1986 and 1987 tax years;
19. if any underpayments exist, whether the underpayments
of tax for Michoff, Jr., are due to negligence or disregard of
rules or regulations;
20. whether Michoff, Jr., substantially understated his tax
for the 1988 tax year; and
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