T.C. Memo. 1997-353
UNITED STATES TAX COURT
RANDALL L. KIRST and MARY M. KIRST, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22189-95. Filed July 31, 1997.
Curt R. Craton, for petitioners.
Willis B. Douglass, for respondent.
MEMORANDUM OPINION
WRIGHT, Judge: Respondent determined a deficiency of
$25,561 in petitioners' Federal income tax for taxable year 1990.
Respondent further determined that petitioners are liable for the
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