T.C. Memo. 1997-132
UNITED STATES TAX COURT
MARK D. AND SHELDON C. MORGAN, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15590-94. Filed March 13, 1997.
Lewis R. Wiener, for petitioners.
Daniel J. Parent, for respondent.
MEMORANDUM OPINION
JACOBS, Judge: By separate notices of deficiency, both dated
May 27, 1994, respondent determined the following deficiencies and
accuracy-related penalties with respect to petitioners' Federal
income taxes:
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