T.C. Memo. 1997-532
UNITED STATES TAX COURT
DENNIS C. GANDY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
DENNIS C. GANDY AND CAROLYN S. GANDY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 26018-93, 26028-93. Filed December 1, 1997.
William A. Roberts and Jeffrey C. Adams, for petitioners.
Shelley D. Turner and Audrey M. Morris, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge:1 Respondent determined deficiencies in
Federal income tax and additions to tax for petitioners Dennis C.
and Carolyn S. Gandy as follows:
1 These consolidated cases were tried before Judge Edna G.
Parker. Judge Parker died after completion of the trial. The
parties were afforded an opportunity for a new trial, in whole or
in part, but they consented to disposition of the cases on the
record of the trial before Judge Parker.
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